Medford Public Schools COORDINATED PROGRAM REVIEW REPORT OF FINDINGS Dates of Onsite Visit: May 23-June 3, 2005 Date of Draft Report: August 23, 2005 Due Date for Comments: September 16, 2005 Date of Final Report: January 6, 2006 Action Plan Due: February 27, 2006 Department of Education Onsite Team Members: Donna Feinberg-Chairperson Karen DeCoster Ramona Foster Gary Gomes Doreen Iovanna Marnie Jain Jean Jonker Jenna Mancini Kathy McArdle Lindsey McGovern Janis McManus Juan Tapia Elizabeth Young Neil Doherty-Safety Specialist MA DOS K.P. Marshall & Associates, Financial Auditors David P. Driscoll, Commissioner of Education MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Medford Public Schools Table of Contents OVERVIEW OF REVIEW PROCEDURES REPORT INTRODUCTION EXECUTIVE SUMMARY DEFINITION OF TERMS COMPONENT I: ASSESSMENT OF STUDENTS 3 6 8 16 18 SPECIAL EDUCATION ......................................................................................................................................... 19 CAREER AND TECHNICAL EDUCATION ......................................................................................................... 30 ENGLISH LEARNER EDUCATION ..................................................................................................................... 32 COMPONENT II: STUDENT IDENTIFICATION AND PLACEMENT 33 SPECIAL EDUCATION ......................................................................................................................................... 34 CIVIL RIGHTS METHODS OF ADMINISTRATION .......................................................................................... 41 TITLE 1 ................................................................................................................................................................... 46 CAREER AND TECHNICAL EDUCATION ......................................................................................................... 47 ENGLISH LEARNER EDUCATION ..................................................................................................................... 48 COMPONENT III: PARENTAL INVOLVEMENT 52 SPECIAL EDUCATION ......................................................................................................................................... 53 CIVIL RIGHTS METHODS OF ADMINISTRATION .......................................................................................... 59 TITLE 1 ................................................................................................................................................................... 61 SAFE AND DRUG FREE SCHOOLS .................................................................................................................... 62 CAREER AND TECHNICAL EDUCATION ......................................................................................................... 64 ENGLISH LEARNER EDUCATION ..................................................................................................................... 65 COMPONENT IV: CURRICULUM AND INSTRUCTION 67 SPECIAL EDUCATION ......................................................................................................................................... 68 CIVIL RIGHTS METHODS OF ADMINISTRATION .......................................................................................... 76 TITLE 1 ................................................................................................................................................................... 79 SAFE AND DRUG FREE SCHOOLS .................................................................................................................... 81 CAREER AND TECHNICAL EDUCATION ......................................................................................................... 81 ENGLISH LEARNER EDUCATION ..................................................................................................................... 86 COMPONENT V: STUDENT SUPPORT SERVICES 89 SPECIAL EDUCATION ......................................................................................................................................... 90 CIVIL RIGHTS METHODS OF ADMINISTRATION .......................................................................................... 95 TITLE 1 ................................................................................................................................................................. 101 CAREER AND TECHNICAL EDUCATION ....................................................................................................... 102 Medford Public Schools Coordinated Program Review Final Report Page 2 of 152 ENGLISH LEARNER EDUCATION ................................................................................................................... 103 COMPONENT VI: FACULTY, STAFF AND ADMINISTRATION 105 SPECIAL EDUCATION ....................................................................................................................................... 106 CIVIL RIGHTS METHODS OF ADMINISTRATION ........................................................................................ 110 TITLE 1 ................................................................................................................................................................. 111 CAREER AND TECHNICAL EDUCATION ....................................................................................................... 112 ENGLISH LEARNER EDUCATION ................................................................................................................... 112 COMPONENT VII: SCHOOL FACILITIES 114 SPECIAL EDUCATION ....................................................................................................................................... 115 CIVIL RIGHTS METHODS OF ADMINISTRATION ........................................................................................ 115 CAREER AND TECHNICAL EDUCATION ....................................................................................................... 116 ENGLISH LEARNER EDUCATION ................................................................................................................... 117 COMPONENT VIII: PROGRAM PLAN AND EVALUATION 118 SPECIAL EDUCATION ....................................................................................................................................... 119 CIVIL RIGHTS METHODS OF ADMINISTRATION ........................................................................................ 119 TITLE 1 ................................................................................................................................................................. 121 SAFE AND DRUG FREE SCHOOLS .................................................................................................................. 124 CAREER AND TECHNICAL EDUCATION ....................................................................................................... 125 ENGLISH LEARNER EDUCATION ................................................................................................................... 127 COMPONENT IX: RECORD KEEPING 128 SPECIAL EDUCATION ....................................................................................................................................... 129 TITLE 1 ................................................................................................................................................................. 131 SAFE AND DRUG FREE SCHOOLS .................................................................................................................. 137 CAREER AND TECHNICAL EDUCATION ....................................................................................................... 138 ENGLISH LEARNER EDUCATION ................................................................................................................... 140 APPENDIX I: 142 NUTRITION PROGRAMS AND SERVICES ...................................................................................................... 143 APPENDIX II:147 SCHOOL DISTRICT PROFILE INFORMATION ............................................................................................................. 148 Medford Public Schools Coordinated Program Review Final Report Page 2 of 152 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW REPORT Medford Public Schools OVERVIEW OF REVIEW PROCEDURES As one part of its Accountability System, the Department of Education oversees local compliance with education requirements through the Coordinated Program Review System (CPR). All reviews include the following selected requirements: special education under the federal Individuals with Disabilities Education Act (IDEA-97), and M.G.L. Chapter 71B (Chapter 766 of the Acts of 1972); federal civil rights requirements under Title VI of the Civil Rights Act of 1964, the Equal Educational Opportunities Act of 1974, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, and Title II of the Americans with Disabilities Act of 1990, together with related state requirements under M.G.L. Chapter 76, Section 5 (Chapter 622 of the Acts of 1971) and other Massachusetts General Laws; targeted standards from the Board of Education’s Physical Restraint regulations (603 CMR 46.00); targeted standards from the Board of Education’s Student Learning Time regulations (603 CMR 27.00); targeted standards from the federal McKinney-Vento Homeless Education Assistance Improvements Act of 2001 (included in the No Child Left Behind Act of 2001); and provisions of M.G.L. c. 71A, the state law that governs the provision of education to limited English proficient students. Note that due to the voters’ approval in 2002 of an initiative petition entitled “Question 2,” M.G.L. c. 71A has been significantly amended. Under the amended Chapter 71A, limited English proficient students, now referred to as “English learners,” must be provided instruction in sheltered English immersion or two-way bilingual programs unless they have received a waiver. As a result of this change in the law, the Department’s Coordinated Program Review standards under Chapter 71A were significantly revised for the 2003-2004 school year. All districts that enroll limited English proficient students will be reviewed using these updated standards during the 2004-2005 school year. Additional program areas reviewed during the Coordinated Program Review visits in selected districts may include: Title I of the Elementary and Secondary Education Act of 1965, including other related grants funded by the No Child Left Behind Act of 2001; Safe and Drug-Free Schools and Communities Act; Career and Technical Education requirements under the federal Perkins Vocational and Applied Technology Education Act and M.G.L. c. 74; Innovative assistance programs funded under Title V of the No Child Left Behind Act; and Nutrition Programs and Services. The Department’s 2004-2005 schedule of Coordinated Program Reviews is posted on the Department’s web site at <<http://www.doe.mass.edu/pqa/review/cpr/schedule.html>>. The statewide six-year Program Review cycle together with the Department’s Mid-cycle Special Education follow-up monitoring schedule is posted at <<http://www.doe.mass.edu/pqa/review/cpr/6yrcycle.html>>. Medford Public Schools Coordinated Program Review Final Report Page 3 of 152 Coordinated Program Review Elements Team: Depending upon the size of a school district and the number of program areas to be reviewed, a team of two to eight Department staff members together with any necessary outside consultants conducts a Coordinated Program Review over two to ten days in a school district or charter school. Scope: Fifty-five school districts and charter schools are scheduled to receive visits in school year 2004-2005. All school districts and charter schools in the Commonwealth are monitored through the Department's Coordinated Program Review system on a six-year cycle with an additional mid-cycle special education follow-up visit. Content: The Program Review criteria encompass the required elements for the specific program areas. In the case of special education, the elements selected for the 2004-2005 reviews contain, at a minimum, those required by the federal Office for Special Education Programs (OSEP) and revised requirements included under IDEA-97 as described in the Department's Special Education Advisories. Additionally, the 2004- 2005 reviews incorporate state special education requirements as adopted by the Board of Education and effective on December 20, 2000. The Program Review compliance criteria selected in all of the regulated program areas are those that are most closely aligned with the goals of the Massachusetts Education Reform Act of 1993, and intended to promote high standards and achievement for all students. Report: The Department's report is based on a review of written documentation and data regarding the operation of the district's programs, together with information gathered through the following Department program review methods: Interviews of administrative, instructional, and support staff across all grade levels. Interviews of parent advisory council (PAC) representatives and other interviews as requested by persons from the general public. Student record reviews in the program areas of special education, English learner education (c. 71A), Career and Technical Education, and Section 504 (student accommodation plans). A representative sample of student records is selected by the Department. Student records are examined by the onsite team using standard Department student record review procedures to make determinations regarding the implementation of procedural and programmatic requirements. Parents of students with disabilities whose files are selected for the record review are sent a survey that solicits information regarding their experiences with the district’s implementation of special education programs, related services and procedural requirements. Classroom and facilities observation. The onsite team visits a sample of instructional classrooms and other school facilities used in the delivery of programs and services to determine general levels of compliance with program requirements. Collaborative programs and services. Where the district is a member of a collaborative approved by the Department of Education and is a site for programs or services operated by the collaborative, interviews, student record review, and classroom and facility observations are conducted for the collaborative. Medford Public Schools Coordinated Program Review Final Report Page 4 of 152 An Executive Summary and detailed findings for each program area describe determinations of the Department about the implementation status of each requirement (criterion) reviewed. Response: In the Final Report the team notes those criteria that it found to be substantially implemented or whose implementation it found to be commendable. Where criteria are found not to be implemented fully, the local district or charter school must propose corrective actions to bring those areas into compliance with the respective statutes or regulations. School districts and charter schools must demonstrate effective resolution of noncompliance identified by the Department as soon as possible but in no case later than one year from the issuance of the Department’s Final Program Review Report. The Department believes that the Coordinated Program Review process is a positive experience and that the Final Report is a helpful planning document for the continued development and improvement of programs and services in each school district, charter school, and educational collaborative. Medford Public Schools Coordinated Program Review Final Report Page 5 of 152 REPORT INTRODUCTION A fourteen-member Massachusetts Department of Education team visited Medford Public Schools during the week of May 23, 2005 to evaluate the implementation of selected criteria in the program areas Special Education, Civil Rights, Title I, English Learner Education (c. 71A), Career and Technical Education, Safe and Drug Free Schools and Nutrition. The team appreciated the opportunity to interview staff and parents, to observe classroom facilities and to review the programs underway in the district. The onsite team would like to commend the following areas that were brought to its attention and that it believes have a significant and positive impact on the delivery of educational services for students enrolled in the Medford Public Schools. These areas are as follows: The district demonstrates a strong proactive commitment to creating and developing in-district options to allow students, ages three through twenty-one, to remain in the community, and to providing support services to families and schools through collaborations with community agencies, local organizations, businesses and universities. There are ongoing initiatives to afford all students in the school communities, inclusionary programming in the least restrictive educational environment. The district demonstrates excellent practices in the oversight and monitoring of the IEP process for students placed in out-of-district placements. The district implements quality alternative middle and high school programs: the Fulton Heights School and the Curtis Tufts School, through a partnership with Tufts University. Strong community partnerships and support contribute to the 100% placement rate for students enrolled in Vocational Technical Education (VTE) programs. Medford Vocational Technical High School demonstrates a commitment to community service learning. Students are required to provide 60 hours of community service (15 hours per year) as a graduation requirement. Procedures and referrals are in place to ensure that homeless children and youth enrolled in the schools receive all services for which they are eligible. Health care services are provided to homeless families in the community through the district’s collaboration with health care and medical agencies. Medford Public Schools participates at an exemplary level with other agencies in activities that include student, parent and teacher surveys, focus groups, program development and implementation, writing grants, evaluation and meetings regarding the prevalence of drugs and violence in the community. An exemplary partnership exists in the district’s collaboration with local agencies implementing local, federal and state programs for drug-abuse and violence prevention for the schools and community The district has very clear expectations against violence and the illegal use of drugs with appropriate, clear, consistent and well-enforced consequences in place for violation of policies. Anti-drug and anti-abuse programs and activities are crafted on scientifically based research and evaluation that demonstrate evidence of program effectiveness in reducing and preventing drug use, violence and disruptive behavior among youth. There is an exemplary process in place to determine the current level of substance abuse and violence among the student population in the community. Medford Public Schools Coordinated Program Review Final Report Page 6 of 152 Some of the commendations noted above are repeated within the body of the Department’s report under the appropriate compliance criteria. The Department is submitting the following Coordinated Program Review Report containing findings made pursuant to this onsite visit. In preparing this report, the team reviewed extensive written documentation regarding the operation of the district's programs, together with information gathered by means of following Department program review methods: Interviews of 32 administrative staff. Interviews of 133 teaching and support services staff across all levels. Interviews of 2 parent advisory council (PAC) representatives. Interviews as requested by persons from the general public. Student record reviews: A sample of 91 student records was selected by the Department. Student records were first examined by local staff, whose findings were then verified by the onsite team using standard Department of Education student record review procedures to make determinations regarding the implementation of procedural and programmatic requirements. Parent surveys: 54 parents of students with disabilities were sent surveys that solicited information regarding their experiences with the district’s implementation of special education programs, related services and procedural requirements. 29 of these parent surveys were returned to the Department of Education for review by the onsite team. Observation of classrooms and other facilities. A sample of 49 instructional classrooms and other school facilities used in the delivery of programs and services was visited to determine general levels of compliance with program requirements. The report includes findings in the program areas reviewed organized under nine components . These components are listed in the executive summary on the following pages. The findings in each program area explain the “ratings, ”determinations by the team about the implementation status of the criteria reviewed. The ratings indicate those criteria that were found by the team to be substantially “Implemented” or implemented in a “Commendable” manner. (Refer to the “Definition of Terms” section of the report.) Where criteria were found to be either "Partially Implemented" or "Not Implemented," the district or charter school must propose to the Department corrective actions to bring those areas into compliance with the controlling statute or regulation. In some instances the team may have rated a requirement as “Implemented” but made a specific comment on the district’s implementation methods that also may require response from the district or charter school. Districts are expected to incorporate the corrective action into their district and school improvement plans, including their professional development plans. Medford Public Schools Coordinated Program Review Final Report Page 7 of 152 COORDINATED PROGRAM REVIEW REPORT EXECUTIVE SUMMARY Medford Public Schools The following summary synthesizes the findings for criteria included in the Coordinated Program Review as they respond to essential questions that the Department has formulated for each of the components of the report. Note that a more detailed discussion of the onsite team’s findings, together with the specific legal standards for each program area included in this review, follows this summary. Component I: Assessment of Students Has the district implemented an assessment system that uses appropriate instruments, is conducted according to the specified timelines, and covers the appropriate content areas to determine instructional needs of students? The district uses assessment instruments that are current, valid and examined to ensure that they are free of bias. Appropriate credentialed and certified personnel conduct evaluations. The district substantially adheres to the IEP process and procedures regarding the completion of evaluations and the provision of in-district and out-of-district IEPs to parents/guardians. Annual reviews and re-evaluations are conducted within the mandated timelines. There are inconsistencies in the type of documentation that is provided to parents at the conclusion of Team meetings when the proposed IEP is not given. The district has assigned an Evaluation Team Leader to each school building to establish system-wide consistency and compliance in the implementation of the in-district IEP process and procedures. However, the selection of assessments for initial and re-evaluations and the completed assessment reports do not always address the specific areas of the student’s need and suspected disability. IEP Teams at the preschool, elementary and middle school levels, including both alternative schools, have the required Team participants and have a person in attendance with the authority to commit the resources of the district. However, at the secondary level, the high school and vocational school do not always have a regular education teacher in attendance. Transition services are considered by IEP Teams for students 14 years or older with students either in attendance at Team meetings or in some manner, participating in the IEP process to ensure their input. Progress reports are issued to parents/guardians according to the report card cycle. However, the progress reports do not always address the progress or lack of progress made towards the annual IEP goals. When students were not making progress, evidence that the IEP Team had convened to address the lack of progress was inconsistent. All students with disabilities participate in the MCAS or the appropriate alternate assessment as determined by the IEP Team. In the area of English Learner Education, limited-English proficient students (LEP) are annually assessed for their level of language proficiency by qualified staff. All LEP students participate in the MCAS with appropriate accommodations. In the area of Career and Technical Education, the district does not use academic and career/vocational assessments for planning students’ programs. Medford Public Schools Coordinated Program Review Final Report Page 8 of 152 Component II: Student Identification and Program Placement Has the district followed procedures for student identification and placement into the program according to the criteria specified in regulations? The district continues to demonstrate a commitment to offering students a wide range of programs and services, which promotes inclusion and integration in the least restrictive educational environment and creates more options for meeting all students’ needs in a diversified learning environment. The schools have a strong partnership with community agencies, hospitals and the police, for outreach and the provision of support services to students and families. However, the vocational school does not always ensure that students with disabilities are provided with full access to the general curriculum in the least restrictive setting. The district adheres to the current structured learning time requirements. IEP Teams consider a student’s need for an extended school year service or program. There is a description of multiple, objective, educationally related criteria for each grade served for those students entering Kindergarten to grade 5 . Preschool and kindergarten screenings are conducted to identify children and students in need of special education services and/or programs. The district has established a strong partnership with Early Intervention Programs. This has resulted in a solid transition process for children moving into preschool programs and ensures that services are in place when the eligible child turns three. IEPS are developed with all the required elements. IEP goals, in most cases, are well written and specific to the student’s area of educational need at the preschool through middle school levels, including the alternative schools. However, the IEP goals at the secondary level, specifically the high school and the vocational school, are not always measurable and do not always pertain to the student’s need for specialized instruction. IEPs at the vocational school do not always include goals specific to the career/vocational and technical program, when necessary and appropriate. Students with social-emotional and behavioral needs who are placed in inclusion classrooms, do not always have IEP goals to address behaviors, when necessary and appropriate. In the area of civil rights, an exemplary level of procedures and referrals are in place that ensure that homeless children and youth enrolled in the schools receive all services for which they are eligible. There is a strong collaboration with the nurses, Board of Health, medical agencies and hospitals in providing health care to the homeless families in Medford. Limited English Proficient (LEP) students are appropriately identified and provided with English language support programs through “sheltered English immersion” classrooms. The content objectives are clear and students are actively participating and engaged in the curriculum. However, there are no formal exit criteria in place across the system, in order to determine when students are ready to leave the English Language Learner programs. Some schools are conducting transition meetings for students, but there is a lack of documentation regarding the procedures implemented to re-designate a student from LEP to Formerly English Proficient (FLEP). Students placed in resource rooms and students in SEI classrooms at the middle and high school do not always have full and equal access to science and tech labs and to Medford Public Schools Coordinated Program Review Final Report Page 9 of 152 exploratory/elective classes. In the career/vocational and technical education programs, there is no evidence that students with limited English proficiency, economically disadvantaged students or nontraditional students are appropriately identified for and/or receive adequate support services. Component III: Parental Involvement Has the district ensured that parents are notified in the appropriate language and are involved in decisions regarding their children's programs and services? Where appropriate, does the district involve community representatives in shaping programs? Parents actively participate in the entire IEP process throughout the school year. Parents have high attendance at Team meetings. The district does whatever is necessary to ensure that parents can attend or participate in the decision making process in an alternate manner. Notices are sent to parents regarding evaluations, parental consent and Team meetings according to federally mandated timelines. There is no formal mechanism for teachers and evaluators to obtain updated information on the type of language assistance that a parent/guardian requires in having full access to the IEP process and procedures. There is inconsistency in the translation of the mandated IEP documents for evaluations and the IEP process. Currently the district is re-evaluating the roles and responsibilities of the district and the special education Parent Advisory Council(PAC) and is seeking to develop a more effective mechanism for the PAC to act as representative for all parents of special education students in the district. The Title I Parent Coordinator shares extensive resources with the parents of Title I students to enable them to improve their children’s achievement. The district should become more involved and supportive of many of the required parent involvement activities. In the area of civil rights, the district needs to ensure that each school has updated information on the type of language assistance required by parents or guardians, whose primary language is not English, to ensure that parents are receiving information in a manner that they can understand. The Homeless Education Liaison is implementing the requirements to fully inform and involve parents and guardians of homeless students in their child’s education and to collaborate with state and community agencies, and the schools, to ensure the provision of education and related services to homeless children and youth. In the area of Safe and Drug Free Schools (SDFS), the Medford SDFS Coordinator maintains consultation in a timely and meaningful way with community agencies, parents, students, schools, police and fire departments, school staff, the medical profession and groups/agencies with interest or expertise in drug and violence prevention, in the development and implementation of the Safe and Drug Free Schools programs and activities. Some of these excellent collaborations with community agencies have provided additional funding, and programs and activities in drug and violence prevention, for students, parents and staff. In the area of Career and Technical Education, the General Advisory Committee, program advisory committees and parents/guardians have limited involvement in the development, implementation and evaluation of career and technical programs. Information regarding career and technical programs is not provided in languages other than English. Medford Public Schools Coordinated Program Review Final Report Page 10 of 152 There is no formal mechanism in place for outreach and to involve parents/guardians of English Language Learners in matters pertaining to their children’s education. Teachers in individual ELE programs are highly involved with their students’ parents. There was evidence of ongoing communications and contact with the parents and the provision of assistance or notification when necessary and requested by the parents/guardians. Component IV: Curriculum and Instruction Does the district hold all students to high expectations and standards? Are programs designed to maximize student performance and students’ participation in the general curriculum? Is curriculum throughout the districts’ programs aligned with the Massachusetts Curriculum Frameworks? Has the district provided for coordination across program areas? The district is committed to the continuous development and expansion of a general curriculum and continuum of services from grades Kindergarten-12 that promote a high quality standards-based curriculum and is responsive to the diverse learning needs of the student population. The general curriculum is aligned with the Massachusetts Curriculum Frameworks and the English Learner Education (ELE) curriculum is based upon the Massachusetts English Language Proficiency Benchmarks and Outcomes. The Medford Early Education Program (MEEP) offers several program options, including a fully integrated developmentally-based classroom model and a full spectrum of related services, to serve young children three and four years of age. The district has excellent procedures in place to monitor the implementation of IEPs for students placed in out-of-district settings. The school year schedules adhere to the state requirements for structured learning time for students from Kindergarten through high school. All students have equal opportunity to participate in extracurricular activities. Concerns exist regarding the available resources and the level of staff awareness and knowledge in the use of assistive technology software and equipment within the K-12 curriculum. IEP Teams do not always consider the student’s need for assistive technology. The district adheres to the class size and age span requirements at the elementary level, but do not fully monitor these requirements at the high school level. In the ELE program, the district needs to review the make-up of instructional groupings as some classrooms have students of differing ages with mixed proficiency levels, rather than similar proficiency levels. In addition, procedures need to be in place system-wide for implementing parental notification and declining entry to an English language support program. The Title I teachers provide reading and language arts support at the elementary level. Title I services are provided in regular education classes using current and scientificallybased instructional strategies to help maximize student achievement. The SDFS coordinator provides coordination with all Program Directors/Coordinators, Administrators and other members of the community to address specific needs in the development and implementation of all programs and activities for students, staff and parents. Medford Public Schools Coordinated Program Review Final Report Page 11 of 152 In general, Medford Vocational Technical High School (MVTHS) students are not held to the same rigorous standards and expectations as are students enrolled at Medford High School (MHS). For example, MVTHS students are required to select one of two curricula: the career curriculum for those interested in employment after high school, or the dual curriculum for students interested in continuing their program at a postsecondary technical college. Shops and academic classrooms have insufficient technology to assist students with technical skill attainment and academic success. Component V: Student Support Services Has the district ensured that all students have equal access to programs and services? Does the district provide support to students who need it? The district uses an integrated support services approach, from preschool to high school , to unify the focus of service delivery for the individual student with the classroom curriculum experiences across the school day. IEP Teams consider a student’s needs for related services and special transportation. The district offers a variety of program options for students requiring therapeutic interventions, which combine school-based services with increased intensive services provided by Wediko Children’s Services or short-term intervention from Tri-City or Arbor Mental Health Services. There are excellent programs within the district for students requiring substantially separate or alternative programming for behavioral and/or social-emotional disorders. However, IEP Teams do not always consider goals and/or interventions, such as the need for counseling services, for students with behavioral and/or social-emotional needs who are placed in full or partial inclusion settings. The district implements the federally mandated procedures regarding suspension and violations of the school’s discipline code for students with disabilities and for students not yet determined eligible for special education services. There is a process in place for tracking and monitoring suspensions for all students. In the area of civil rights, the district must review its school handbooks to develop comprehensive grievance procedures regarding the required steps and timeframe for implementation. In addition, the codes of conduct do not clearly address the consequences that would result from violations of the discipline code. There is no formal mechanism in place for the translation of school handbooks and the code of conduct for parents/guardians whose primary language is other than English and who require or request written and/or oral language assistance. In the ELE program area, students have access to nonacademic and extracurricular activities. However, there is no process in place for students at the middle and high school to receive information, about activities from the guidance department, in a language that they can understand. The district also does not have formal procedures in place to track and monitor the provision of supports and the progress of students exiting from the ELE program for a two-year period. In the area of Title I, the students at the eligible public and private schools receive academic support to help them meet the challenging curriculum. All students who are eligible have access to the Title I services. At Medford Vocational Technical High School, not all students in special education programs Medford Public Schools Coordinated Program Review Final Report Page 12 of 152 have full access to the CVTE programs available. Students who self-identified on their admission applications that their home language was other than English, are neither assessed nor provided support services in their academic or technical courses at the vocational school. Overall, support services are limited and inequitable in comparison with Medford High School. Component VI: Faculty, Staff and Administration Does the district maintain licensed staff in the specific program areas, provide supervision of aides and tutors, and provide ongoing professional development? Are program leadership and oversight effective? Are the district’s personnel procedures non-discriminatory and does it seek to recruit employees from all groups? All special education and related service personnel are appropriately certified and licensed in their area of expertise. There is a high level of informal collaboration and networking among the regular and special education teachers and paraprofessional staff. However, there are limited opportunities for regular and special education teachers, English language teachers and paraprofessionals to be involved in cross-curricular activities through professional development activities and workshops. All teachers in English language classrooms are appropriately certified and qualified to provide instruction. The district has provided quality professional development to professional staff. However, the review team noted a need for increased training in the identification of disabilities, classroom application of instructional strategies and accommodations for different disabilities and diverse learning styles, implementation of behavioral strategies in general education classroom and second language acquisition. The specific training in roles and responsibilities and the provision of regular supervision of the paraprofessional staff varies throughout the district. Some paraprofessionals, especially at the high school and vocational school, are delivering and sometimes, designing instruction. In addition, paraprofessionals do not have access to professional development opportunities on an ongoing basis. The district has implemented a Teacher Assistance Team process that is firmly in place at the elementary and middle school levels regarding the provision of instructional support interventions to students in general education. However, the process is not being implemented at the vocational school or at the high school, where the process is functioning as a referral to special education, rather than an intervention process. The Title I staff and teachers have met the licensure requirements. The teachers interviewed have a passion for teaching and demonstrate a genuine interest in student academic achievement. There is a sharing of resources both tangible and intangible. Not all vocational technical education (VTE) teachers in Chapter 74-approved vocational technical education programs are appropriately certified. One Algebra/MCAS preparation teacher is not certified to teach mathematics. (CTE) Component VII: School Facilities Does the district maintain accessible facilities that are conducive to learning, facilitate integration, and provide equal opportunity for students to achieve? The district has a school at every level that provides full accessibility. The space provided for Medford Public Schools Coordinated Program Review Final Report Page 13 of 152 the middle and high school special education resource room and the middle school ELE classroom are not comparable with spaces provided for regular education. In addition, the location of the life skills program at the McGlynn Elementary school does not maximize the integration of the students with their peer group in the general education program. During the review, a safety expert contracted by the Department carried out a safety inspection of Medford Vocational High School’s shops and related facilities. The safety expert identified 68 serious safety hazards that will require immediate corrective action. Serious hazards are defined as those that can cause an accident or health hazard exposure resulting in death or serious harm. Of the 68, the expert identified items 1, 2, 3, 14, 21, 27, 29, 30, 31 and 32 to be approaching imminent danger to students and staff. Safety training is not provided to all staff and there is no school-wide Safety Plan. None of the 12 shops inspected were in full compliance with applicable Occupational Safety and Health Administration (OSHA) regulations. Jeffrey Wheeler, State Director of Career/Vocational Technical Education sent the report prepared by the safety expert to Superintendent Belson and Principal Mahoney on July 5, 2005. The district must begin rectifying the hazards immediately. All safety hazards must be corrected prior to the opening of the 2005-2006 school year.(CTE) Component VIII: Program Plan and Evaluation Does the district evaluate its programs in accordance with regulatory requirements? Does it use the results of its evaluations to improve programs? Do parents have opportunities for input on program needs, program implementation, and program evaluation and improvement? The district, through the work of the Medford Human Rights Commission and Racially Balanced Advisory Committee, regularly track multicultural and multiracial efforts as evidenced in the K-12 curriculum. There is an annual review of Homeless Policies, K-12 programs and counseling materials to ensure that they are free of bias and stereotypes. However, there is a need to develop a formal mechanism to evaluate all aspects of the K-12 program in regards to the nondiscrimination policy, as inconsistencies and inequities were noted in the area of disproportionality, the implementation of the regular curricular requirements at the secondary level for all students and the equitability of the resource room spaces at the secondary level. The Special Education Administrator meets regularly with the Special Education Coordinators, Evaluation Team Leaders and staff to review and evaluate the effectiveness and appropriateness of the special education programs and services system-wide. However, there is no formal process or plan in place to regularly review the district’s programs and services, or document the evaluation outcomes and the changes implemented as a result. The district also does not have a process in place to conduct periodic evaluations of the effectiveness of its English Learner Education program. The Title I Program provides opportunities for administrators, professional staff, Title I teachers/reading specialist and parents to assess the program through surveys. The Title I program has changed some of its instructional focus based on the needs at each school. Medford has an exemplary process in place to determine the current level of substance abuse and violence problems among students in the community. The district has established goals, Medford Public Schools Coordinated Program Review Final Report Page 14 of 152 measurable objectives and activities for its prevention programs that address the needs identified by the objective analysis. Programs are crafted on scientifically based research and evaluation that demonstrate evidence of program effectiveness in reducing and preventing drug use and disruptive behaviors among youth. Components that have been implemented include: Second Step, Bullying Program, Peer Mediation, Smoking Cessation, Gay Straight Alliance, Teen Dating Violence, and SADD. The district has an evaluation process in place to measure progress toward achieving its goals and objectives in these programs. There is evidence that evaluation results are used to refine, improve and strengthen the local programs and activities and the SDFS program results are reported publicly on a consistent basis. While placement data is used to evaluate program success, there is no additional system of evaluation of career/vocational technical programs. Component IX: Record keeping Does the District maintain required records and documentation for each program area? Are entitlement grants appropriately designed, amended, and monitored? Does the district use federal grant funds in accordance with statutory fund-use rules, including supplement not supplant provisions where applicable? Does the district meet applicable maintenance of effort requirements? The district implements the appropriate record keeping requirements in the area of special education, regarding eligible students. Federal grants are designed by the appropriate administrators and monitored to ensure full implementation. Title I Programs’ grant, files and documentation are well maintained and complete. The required records are in excellent order. The files and reports relating to the fiscal requirements are complete and on file in the appropriate offices. Appropriate accounting documentation, for the Safe and Drug Free Schools Community Act grant, demonstrates that procedures are in place and approved budgets and amendments are on file for fiscal years 2004 and 2005. Expenditures are strictly related to the intent of the grant. Time distribution logs are maintained for individuals funded under SDFSCA funds. Medford conveys a clear message that acts of violence and illegal drug use are wrong and harmful. The set of assurances, schools discipline policies, security procedures and crisis management plans all include the required information for keeping schools safe and drug free. The records of Limited English Proficient students do not contain all the required documentation. Records for students enrolled in career/vocational technical programs/courses are incomplete. Several student records contain information of other students due to misfiling. Medford Public Schools Coordinated Program Review Final Report Page 15 of 152 DEFINITION OF TERMS FOR THE RATING OF EACH COMPLIANCE CRITERION Commendable Any requirement or aspect of a requirement implemented in an exemplary manner significantly beyond the requirements of law or regulation. Implemented The requirement is substantially met. Partially Implemented The requirement, in one or several important aspects, is not entirely met. Not Implemented The requirement is totally or substantially not met. Not Applicable The requirement does not apply to the school district or charter school. Several key areas of compliance with federal special education requirements have been highlighted in SHADED TEXT in the Program Review Criteria. These highlighted areas are included in the Massachusetts Continuous Improvement Plan (CIP) that is being used by the U.S. Department of Education, Office of Special Education Programs (OSEP), to track over time this state’s compliance in these key areas. Medford Public Schools Coordinated Program Review Final Report Page 16 of 152 School District: Medford Public Schools SUMMARY OF COMPLIANCE CRITERIA INCLUDED IN THIS REPORT RECEIVING A COMMENDABLE RATING FROM THE DEPARTMENT OF EDUCATION Special Education SE 37 Safe and Drug Free Schools SDF 2, SDF 2A SDF 5, SDF 7 Civil Rights MOA 2C MOA 6B SUMMARY OF COMPLIANCE CRITERIA INCLUDED IN THIS REPORT REQUIRING CORRECTIVE ACTION PLAN DEVELOPMENT in response to the following COORDINATED PROGRAM REVIEW REPORT FINDINGS PARTIALLY IMPLEMENTED NOT IMPLEMENTED OTHER CRITERIA REQUIRING RESPONSE Special Education(SE): 1, 2, 3, 4, 8, 9, 13, 18A, 18B, 19, 20, 22, 23, 24, 28, 29, 32, 33, 35, 40, 41, 43, 48, 49, 50, 53, 54, 55, 56 Civil Rights (MOA): 1, 3, 4, 7, 9, 10A, 11A, 12A, 13, 14, 15, 23 Career/Vocational and Technical Education ( CTE): 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 19, 20, 21, 22 MOA 18A , 25 CTE 18, 23 English Learner Education (ELE): 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16, 17, 18 Nutrition (NS): 1, 3, 4, 5, 6 NOTE THAT ALL OTHER CRITERIA REVIEWED BY THE DEPARTMENT THAT ARE NOT MENTIONED ABOVE HAVE RECEIVED AN “IMPLEMENTED” RATING. Medford Public Schools Coordinated Program Review Final Report Page 17 of 152 COMPONENT I: ASSESSMENT OF STUDENTS The criteria in this component examine whether the District has implemented an assessment system that uses appropriate instruments, conducted according to the specified timelines and covering the appropriate content areas to determine instructional needs of students for the program areas listed below: Special Education (Report Issues # SE 1-14) Career and Technical Education (Report Issues # CTE 1-3) English Learner Education (Report Issues # ELE 1-2) Medford Public Schools Coordinated Program Review Final Report Page 18 of 152 CRITERION NUMBER SPECIAL EDUCATION I. ASSESSMENT OF STUDENTS Legal Standard SE 1 j. Assessments are appropriately selected and interpreted for students referred for evaluation 1. Tests and other evaluation materials are: a. validated b. administered and interpreted by trained individuals c. tailored to assess specific areas of educational need d. selected and administered to reflect aptitude and achievement levels e. as free as possible from cultural and linguistic bias f. provided in the student's native language or other mode of communication where feasible g. not the sole criterion for determining an appropriate educational program h. not only those designed to provide a single general intelligence quotient i. are selected and administered to ensure that when a test is administered to a student with impaired sensory, manual, or speaking skills, the test results accurately reflect the student's aptitude or achievement level or the other factors the test purports to measure technically sound instruments that may assess the relative contribution of cognitive and behavioral factors, in addition to physical or developmental factors 2. In interpreting evaluation data and making decisions, the district: a. uses information from a variety of sources to gather relevant functional and developmental information, including information provided by the parent b. ensures that information obtained from these sources is considered c. ensures that the placement decision conforms with placement in the least restrictive environment d. includes information related to enabling the student to be involved in and progress in the general curriculum State Regulations Federal Requirements 28.04 34 CFR 300.532, 300.535 28.05 34 CFR 104.35(b) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Documentation shows that there are a variety of tests available for assessment purposes within the district. Student record review and interviews show that the selection of assessments for initial and re-evaluations do not always adequately address the specific areas of a student’s educational need and suspected disability. In the above cases, the evaluators tend to use a standard battery of assessments for initial evaluations and reevaluations rather than selecting assessments related to the suspected area(s) of disability and individualized to the student. However, interviews indicate that a number of issues effect the staff’s ability to access the tests: time constraints regarding actual time allocated to conduct an evaluation in all areas of suspected disability; lack of knowledge regarding how to select appropriate tests to use as diagnostic tools for different areas of suspected disability; and limited access to the tests available in the district. Medford Public Schools Coordinated Program Review Final Report Page 19 of 152 CRITERION NUMBER Legal Standard SE 2 Required and optional assessments 1. Required assessments: The following assessments are completed by appropriately credentialed and trained specialists for each referred student: a. Assessment(s) in all areas related to the suspected disability (ies) including consideration of any needed assistive technology devices and services and/or instruction in braille. b. Educational assessment by a representative of the school district, including a history of the student’s educational progress in the general curriculum. c. Assessment by a teacher(s) with current knowledge regarding the student’s specific abilities in relation to learning standards of the Massachusetts Curriculum Frameworks and the district curriculum, as well as an assessment of the student’s attention skills, participation behaviors, communication skills, memory, and social relations with groups, peers, and adults. d. For a child being assessed to determine eligibility for services at age three (3), an observation of the child’s interactions in the child’s natural environment or early intervention program is strongly encouraged together with the use of current assessments from early intervention Teams to avoid duplicate testing. 2. Optional assessments: The Administrator of Special Education may recommend or the parent may request one or more of the following: a. A comprehensive health assessment by a physician that identifies medical problems or constraints that may affect the student's education. The school nurse may add additional relevant health information from the student’s school health records. b. A psychological assessment by a certified school psychologist, licensed psychologist, or licensed educational psychologist, including an individual psychological examination. c. A home assessment that may be conducted by a nurse, psychologist, social worker, guidance or adjustment counselor, or teacher and includes information on pertinent family history and home situation and may include a home visit, with the agreement of the parent 3. At the re-evaluation of a student, if the Team decides that no additional assessments are needed to determine whether the student continues to be eligible for special education, the school district recommends to the student’s parents the following: a. that no further assessments are needed and the reasons for this; and b. the right of such parents to request an assessment. Medford Public Schools Coordinated Program Review Final Report Page 20 of 152 CRITERION NUMBER Legal Standard State Regulations 28.04 (1) and (2) Rating: Partially Implemented Federal Requirements 300.532; 300.346.(a)(2)(v) District Response Required: Yes Department of Education Findings: Refer to SE 1 regarding 1(a). In the area of re-evaluations, interviews indicate that the student’s progress is reviewed, but this information is not always used to guide in the selection of appropriate assessment instruments for the student’s re-evaluation. There is a tendency to re-administer the assessments that were previously identified and completed for the student’s initial evaluation, rather than reviewing existing evidence of achievement from a variety of sources, including but not limited to in-class work, and teacher observations to further evaluate the areas of concern. CRITERION NUMBER Legal Standard SE 3 Special requirements for determination of specific learning disabilities When the district proposes to evaluate a child suspected of having a specific learning disability, the following requirements are implemented: a. Team membership: The district ensures the Team includes at a minimum the parent, the child’s regular classroom teacher appropriate to the age of the child and at least one person qualified to conduct individual diagnostic examinations of children. b. Criteria for determining the existence of a specific learning disability: 1. the achievement is determined not to be commensurate with the age and ability of the child; 2. a severe discrepancy exists in one or more areas between achievement and intellectual ability in oral expression, listening comprehension, written expression, basic reading skill and reading comprehension, mathematics calculation and reasoning; 3. the severe discrepancy between ability and achievement is not resulting from visual, hearing or motor impairment, mental retardation, emotional disturbance or environmental, cultural or economic disadvantage. c. Required observation of the child: 1. at least one Team member other than the child’s regular teacher observes the child’s academic performance in the regular classroom setting; 2. if the child is less than school age, the observation is conducted in an environment appropriate for a child of that age. d. Written documentation of the Team’s determination of eligibility due to the presence of a specific learning disability includes the following: 1. statement whether the child has a specific learning disability; 2. the basis for making the determination; 3. the relevant behavior noted during the observation of the child; Medford Public Schools Coordinated Program Review Final Report Page 21 of 152 CRITERION NUMBER Legal Standard 4. the relationship of that behavior to the child’s academic functioning; 5. the educationally relevant medical findings, if any; 6. statement whether there is a severe discrepancy between achievement and ability that is not correctable without special education and/or related services; and 7. the determination of the Team concerning the effects of environmental, cultural, or economic disadvantage. e. Required written certification of Team members: Each Team member certifies in writing whether the report reflects his or her conclusion. If not, the Team member submits a separate statement presenting his or her conclusions. State Regulations Federal Requirements 34 CFR 300.540-543 District Response Required: No Not Rated Department of Education Findings: Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, until final implementing regulations have been adopted, the Department is not making findings related to school district practices under this criterion. CRITERION NUMBER Legal Standard SE 4 Reports of assessment results 1. Each person conducting an assessment shall summarize in writing the procedures employed, the results, and the diagnostic impression, and shall define in detail and in educationally relevant and common terms, the student’s needs, offering explicit means of meeting them. Assessors may recommend appropriate types of placements, but shall not recommend specific classrooms or schools. 2. Summaries of assessments are completed prior to discussion by the Team and, upon request, are made available to the parent at least two days in advance of the Team discussion. State Regulations Federal Requirements 28.04(2)(c) 300.532 District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Student record review shows that there is not always sufficient and/or consistent interpretation of assessment findings regarding how the student performed. In these cases, assessment reports tend to explain the content of the assessments and report the scores rather than reporting on the student’s performance or presenting educationally relevant findings and recommendations that provide necessary information to the IEP Team regarding the student’s educational needs. Medford Public Schools Coordinated Program Review Final Report Page 22 of 152 CRITERION NUMBER Legal Standard SE 5 Participation in general State and district-wide assessment programs 1. All students with disabilities whose placements are funded by the district are included in the Massachusetts Comprehensive Assessment System (MCAS) and other district-wide assessment programs. 2. The district’s IEP Teams designate how each student will participate and, if necessary, provide an alternate assessment. 3. The superintendent of a school district--or, for a public school program that is not part of a school district, the equivalent administrator— a. files an MCAS performance appeal for a student with a disability when the student’s parent or guardian or the student, if 18 or over, requests it, provided that the student meets the eligibility requirements for such an appeal; b. obtains the consent of the parent or guardian or the student, if 18 or over, for any MCAS performance appeal filed on behalf of a student with a disability; c. includes in the MCAS performance appeal, to the extent possible, the required evidence of the student’s knowledge and skills in the subject at issue. State Requirements Federal Requirements St. 2003, c. 140; 34 CFR 300.138; 300.139 603 CMR 30.05(2),(3),(5) District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard SE 6 Determination of transition services 1. For a student who is 14 years of age, the Team considers the student’s course of study in relation to the student’s future goals and document this in the IEP. 2. For a student who is 16 years of age, or younger if appropriate, the Team includes in the IEP services that promote movement of the student from school to post-school activities, including post-secondary education, vocational training, integrated employment (including supported employment), continuing and adult education, adult services, independent living, or community participation. 3. The transition services are based upon the student's needs, taking into account the student's preferences and interests and includes specially designed instruction, community experiences, the development of employment or other post-school adult living objectives, and, if appropriate, the acquisition of daily living skills and functional vocational evaluation. Medford Public Schools Coordinated Program Review Final Report Page 23 of 152 CRITERION NUMBER Legal Standard 4. For any student approaching graduation or the age of twenty-two, the Team determines whether the student is likely to require continuing services from adult human service agencies. In such circumstances, the Administrator of Special Education makes a referral to the Bureau of Transitional Planning in the Executive Office of Health and Human Services in accordance with the requirements of M.G.L. c.71B, §12A-§12C (known as Chapter 688). 5. In cases where the IEP included needed transition services and a participating agency other than the school district fails to provide these services, the Team reconvenes to identify alternative strategies to meet the transition objectives. 6. The district ensures that students age 14, or younger if appropriate, are invited to and encouraged to attend part or all of Team meetings at which transition services are discussed or proposed State Requirements Federal Requirements M.G.L. Ch.71B, Sections 12A-C 34 CFR 300.344(b), 300.347 603 CMR 28.05(4)(c) District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority 1. One year prior to the student reaching age eighteen, the district informs the student of his or her right at age 18 to make all decisions in relation to special education programs and services. 2. Upon reaching the age of eighteen, the school district implements procedures to obtain consent from the student to continue the student’s special education program. 3. The district continues to send the parent written notices and information but will no longer have decision-making authority, except as provided below. (a) If the parent has sought and received guardianship from a court of competent jurisdiction, then the parent retains full decision-making authority. The parent does not have authority to override any decision or lack of decision made by the student who has reached the age of majority unless the parent has sought or received guardianship or other legal authority from a court of competent jurisdiction (b) The student, upon reaching the age of majority and in the absence of any court actions to the contrary, may choose to share decisionmaking with his or her parent (or other willing adult), including allowing the parent to co-sign the IEP. Such choice is made in the presence of the Team and is documented in written form. The Medford Public Schools Coordinated Program Review Final Report Page 24 of 152 CRITERION NUMBER Legal Standard student’s choice prevails at any time that a disagreement occurs between the adult student and the parent or other adult with whom the student has shared decision-making (c) The student, upon reaching the age of majority and in the absence of any court actions to the contrary, may choose to delegate continued decision-making to his or her parent, or other willing adult. Such choice is made in the presence of at least one representative of the school district and one other witness and is documented in written form and maintained in the student record. State Regulations Federal Requirements 603 CMR 28.08(5) 300.347(c), 300.517 District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard SE 8 Evaluation Team composition The following persons are members of the evaluation Team: 1. The child’s parents 2. A representative of the school district who acts as Chairperson and who is (1) qualified to supervise or provide special education; (2) is knowledgeable about the general curriculum; and (3) is knowledgeable about the availability of resources of the district. 3. A representative of the school district who has the authority to commit the resources of the district (and who may act as the Chairperson) 4. A teacher who has recently had or currently has the student in a classroom or other teaching situation. If the student is involved or may be involved in a regular education program, a regular education teacher must be included as a Team member. 5. The student, age fourteen and older, if he/she chooses 6. Other individuals at the request of the student's parents 7. At least one teacher or specialist trained in the area of the student's suspected special needs 8. Individuals who are qualified to interpret the instructional implications of evaluation results 9. Other individuals who may be necessary to write an IEP for the child, as determined by the Administrator of Special Education 10. When one purpose of the Team meeting is to discuss transition services, the student age sixteen or older (or younger, if appropriate) is a part of Team process. If the student does not attend the Team meeting, the school district ensures that the Team is informed of the student's interests and preferences. 11. When one purpose of the Team meeting is to discuss transition services, a representative of any public agency who may be responsible for providing Medford Public Schools Coordinated Program Review Final Report Page 25 of 152 CRITERION NUMBER Legal Standard or paying for transition services is invited to the Team meeting. If the representative(s) does not attend the meeting, the school district takes other steps to obtain the participation of these agencies. 12. When one purpose of the Team meeting is to discuss vocational education needs, a person knowledgeable about vocational education placement options is present at the meeting. State Regulations Federal Requirements 28.02(22) 34 CFR 300.344; 300.552 District Response Required: Yes Rating: Partially Implemented Department of Education Findings: The IEP Teams at the preschool, elementary and middle school levels are fully represented. However, at the high school level, although guidance staff are often present, there is not always a regular education teacher in attendance to represent knowledge of classroom performance and need. Interviews indicated that not all staff are aware of the plan and procedures in place to ensure that coverage is provided when regular education personnel are required to attend Team meetings. CRITERION NUMBER Legal Standard SE 9 Eligibility determination: Timelines for evaluation, provision of IEP and/or identification of other needed instructional programs 1. Within forty-five school working days after receipt of the parent's written consent to an initial evaluation, unscheduled evaluation, or re-evaluation, the school district: a. provides an evaluation b. convenes a Team meeting c. determines whether the student has one or more disabilities d. determines if the student is making effective progress in school e. determines if any lack of progress is a result of the student’s disability f. determines if the student requires special education and/or related services and/or accommodations in order to make effective progress or that the student requires related services in order to access the general curriculum g. develops an IEP where the student is found to need special education h. provides the parent with the proposed IEP, or a written explanation of the finding of no eligibility i. determines that a student is ineligible to receive special education and/or the student’s lack of progress is due to a lack of instruction in reading or math or limited English proficiency or social Medford Public Schools Coordinated Program Review Final Report Page 26 of 152 CRITERION NUMBER Legal Standard maladjustment, the student is referred to a more appropriate instructional program or support service j. determines at the time of re-evaluation if the student would continue to make progress in school without the provision of special education services. 2. If a Team determines that a student is not eligible for special education but may be eligible for accommodation(s) for disability(ies) under Section 504, the student is referred for consideration by the district for eligibility under that regular education program. 3. When the development of a student’s IEP does not indicate a need for direct services, the Team makes a finding of no eligibility and appropriate services are provided through the district’s general education program. State Regulations 28.05(1) and (2) Federal Requirements 300.534 District Response Required: Rating: Partially Implemented Yes Department of Education Findings: Student record review shows that in some cases, the provision of the proposed IEP and placement to the parent exceeds the mandated 45-day timeframe. CRITERION NUMBER Legal Standard SE 10 End of school year evaluations If consent is received within thirty (30) to forty-five (45) school working days before the end of the school year, the school district ensures that a Team meeting is scheduled so as to allow for the provision of a proposed IEP or written notice of the finding that the student is not eligible no later than fourteen (14) days after the end of the school year.. State Regulations 28.05(1) Federal Requirements 300.342 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 27 of 152 CRITERION NUMBER Legal Standard SE 11 School district response to parental request for independent educational evaluation If a parent disagrees with an initial evaluation or re-evaluation completed by the school district, and the parent requests an independent educational evaluation, the district implements the following requirements: 1. All who abide by the rates set by the state agency responsible for setting such independent educational evaluations funded by the district are conducted by qualified persons who are registered, certified, licensed or otherwise approved and rates. Unique circumstances of the child are justified when an individual assessment rate is higher than that normally allowed. 2. The school district has procedures to offer parents the option of participating in an income eligibility program for free or reduced cost independent educational evaluations that are equivalent to the types of assessments done by the school district. 3. The district extends the right to a publicly funded independent educational evaluation (only if cost shared or funded for state wards or for students receiving free or reduced cost lunch) for sixteen (16) months from the date of the evaluation with which the parent disagrees. 4. If the parent is requesting an evaluation in an area not assessed by the school district, or if the student does not meet or the parent does not choose to share the financial documentation regarding the income eligibility standards for free or reduced cost independent educational evaluation, then the school district responds in accordance with the requirements of federal law by paying for the independent educational evaluation or, within five school days, proceeding to Special Education Appeals to show that its evaluation was comprehensive and appropriate. Where the Department’s Special Education Appeals finds that the school district’s evaluation was comprehensive and appropriate, the school district does not pay for the independent educational evaluation requested by the parent. 5. Whenever possible, the independent educational evaluation is completed and a written report sent no later than thirty (30) days after the date the parent requests the independent educational evaluation. If publicly funded, the report is sent to the parents and to the school district. The independent evaluator’s report summarizes, in writing, procedures, assessments, results, and diagnostic impressions as well as educationally relevant recommendations for meeting identified needs of the student. The independent evaluator recommends appropriate types of placements but does not recommend specific classrooms or schools. 6. Within ten (10) school days from the time the school district receives the report of the independent educational evaluation, the Team reconvenes and considers the independent educational evaluation (which may be publicly or privately funded) and whether a new or amended IEP is appropriate. State Regulations Federal Requirements 28.04(5) 300.502(a)(3)(i) Rating: Implemented District Response Required: No Medford Public Schools Coordinated Program Review Final Report Page 28 of 152 CRITERION NUMBER Legal Standard SE 12 Frequency of re-evaluation 1. Every three years, or sooner if necessary, the school district, with parental consent, conducts a full three-year re-evaluation consistent with the requirements of federal law. 2. The district implements re-evaluation procedures in all cases where it is suspected that a student is no longer eligible for special education. State Regulations 28.04(3) Federal Requirements 300.536 District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard SE 13 Progress Reports and content 1. Parents receive reports on the student's progress toward reaching the goals set in the IEP at least as often as parents are informed of the progress of nondisabled students. 2. Progress report information sent to parents includes written information on the student’s progress toward the annual goals in the IEP, including information on the extent to which such progress is sufficient to enable the child to achieve the goals by the end of the year. State Regulations 28.07(3) Rating: Partially Implemented Federal Requirements 34 CFR 300.347 District Response Required: Yes Department of Education Findings: Review of progress reports shows that reports do not always specifically address the student’s progress toward individual IEP goals and objectives or indicate whether the student will achieve the annual goals by the end of the IEP period. The student record review shows that the district does not always address or document the steps taken when a student is failing to make progress towards the annual IEP goals. Interviews indicate that there were no procedures established system-wide regarding the steps to take when a student is failing to make progress towards the annual IEP goals and/or exhibiting recurring issues in maintaining classroom/school-wide behavior, achieving passing grades or demonstrating consistent school attendance. Medford Public Schools Coordinated Program Review Final Report Page 29 of 152 CRITERION NUMBER Legal Standard SE 14 Annual review Team meeting At least annually, on or before the anniversary date of the implementation of the IEP, a Team meeting (including the major service providers and the parent) is held to consider the student’s progress and to review, revise, or develop a new IEP or refer the student for a re-evaluation, as appropriate. State Regulations 28.04(3) Federal Requirements 300.343(c) District Response Required: Rating: Implemented No CAREER AND TECHNICAL EDUCATION I. ASSESSMENT OF STUDENTS CRITERION NUMBER Legal Standard CTE 1 Appropriate individual academic and career/vocational assessments are administered to all incoming students who will be enrolled in career and technical education programs. Perkins Sections 2, 135; Chapter 74 603 CMR 4.03(4)(d)(e) Examples of Assessments: Career/Vocational Assessments: ACT Career Planning, ACDM, Bennett Mech., CAB, Career Inventories for Learning Disabled, CIT, DISCOVER, Myers Briggs, SAGE, Self-Directed Search (SDS), Other________ Academic Assessments: ABLE, APTICOM, CAT, IOWA, METROPOLITAN, MCAS, Stanford 9, WRAT, Other________ Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Appropriate individual academic and career/vocational assessments are provided to all incoming students who will be enrolled in career and technical education programs. Perkins Sections 2; Chapter 74 603 CMR 4.03(4)(d)(e). Chapter 74 Criteria: Based upon record reviews and interviews with staff, parents/guardians and students, while career/vocational assessments are administered (i.e., Career Cruiser, exploratory assessment, and CDM), no academic assessments are provided to incoming students after admission. Medford Public Schools Coordinated Program Review Final Report Page 30 of 152 CRITERION NUMBER Legal Standard CTE 2 Academic and career/vocational assessments administered to incoming students are used in planning students’ entire academic and technical program of study. Perkins Section 135; Chapter 74 603 CMR 4.03(4)(d)(e) District Response Required: Rating: Partially Implemented Yes Department of Education Findings: Academic and career/vocational assessments provided to incoming students are used in planning students’ entire academic and technical program of study. Perkins sections 135; Chapter 74 603 4.03(4)(d)(e). Perkins and Chapter 74 Criteria: Based upon record reviews and interviews with staff, parents/guardians and students, academic and career/vocational assessments are not used in planning a student’s program of study. With the exception of exploratory assessments used for initial program placement, there is no evidence of planning based upon assessment results. A review of students’ career plan/portfolios suggests that they are not completed by students or reviewed by parents/guardians. Interviews with highly involved parents/guardians indicate that they neither see nor have been asked to review their son/daughter’s career plan/portfolios. CRITERION NUMBER Legal Standard CTE 3 Methods of measuring academic and technical competency gain and competency attainment are appropriate. Perkins Section 135; Chapter 74 603 CMR 4.03 (4)(a)(c)(d) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Methods of measuring academic and technical competency attainment are appropriate. Perkins Section 135; Chapter 74 603 4.03(4)(a)(c)(d) Perkins and Chapter 74 Criteria: Based upon record reviews and interviews with staff, parents/guardians and students, not all career/vocational technical programs have and utilize technical competency checklists. Student portfolios are not rigorous or consistently used as an assessment strategy in all academic and technical courses/programs. Medford Public Schools Coordinated Program Review Final Report Page 31 of 152 CRITERION NUMBER ENGLISH LEARNER EDUCATION I. ASSESSMENT OF STUDENT PROGRESS Legal Standard ELE 1 Annual Assessment 1. The district annually assesses the English proficiency of all limited English proficient (LEP) students. 2. The following tests selected by the Massachusetts Board of Education are administered annually by qualified staff to students who are English learners: (a) the Massachusetts Comprehensive Assessment System (MCAS) in grades 3-12; and (b) the Massachusetts English Proficiency Assessment (MEPA) in grades 3-12, and the Massachusetts English Language Assessment – Oral (MELA-O) in grades K-12. Authority: G.L. c. 71A, § 7; 603 CMR 14.02 District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard ELE 2 MCAS Participation Limited English proficient students participate in the annual administration of the MCAS (Massachusetts Comprehensive Assessment System) exam as required and in accordance with Department guidelines. Authority: GL. C. 71A, § 7; G.L. c. 69, § 1I; N.C.L.B., Title I, Title VI Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 32 of 152 COMPONENT II: STUDENT IDENTIFICATION AND PLACEMENT The criteria in this component examine whether the district has followed procedures for student identification and placement into the program according to the criteria in regulations for the program areas listed below: Special Education (Report Issues # SE 15-23) Civil Rights Methods of Administration (Report Issues # MOA 1-6) Title I (Report Issues # TI 19-20) Career and Technical Education (Report Issues # CTE 4-5) English Learner Education (Report Issues # ELE 3-6) Medford Public Schools Coordinated Program Review Final Report Page 33 of 152 SPECIAL EDUCATION II. STUDENT IDENTIFICATION AND PLACEMENT CRITERION NUMBER Legal Standard SE 15 Outreach by the School District (Child Find) The district has annual or more frequent outreach and continuous liaison with those groups below from which promotion or transfer of students in need of special education may be expected, or which would include students in need of special education: 1. professionals in community 2. private nursery schools 3. day care facilities 4. group homes 5. parent organizations 6. clinical /health care agencies 7. early intervention programs 8. other public/private/parochial schools 9. other agencies/organizations 10. the school itself, including charter schools 11. agencies serving migrant and/or homeless persons pursuant to the McKinney-Vento Education Act for Homeless Children State Regulations Rating: Implemented Federal Requirements 34 CFR 300.125; 300.312 District Response Required: No CRITERION NUMBER Legal Standard SE 16 Screening 1. The school district conducts screening for three and four year olds and for all children who are of age to enter kindergarten. Such screening is designed to review a child’s development and to assist in identification of those children who should be referred for an evaluation to determine eligibility for special education services. 2. 3. Participation in the screening program for three and four year olds is optional on the part of the parents. Provision is made for ongoing and periodic screening of all students as required by the Department of Public Health (vision, hearing, and posture). State Regulations 28.03(1)(d) Chapter 71, Section 57 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report Federal Requirements District Response Required: No Page 34 of 152 CRITERION NUMBER Legal Standard SE 17 Initiation of services at age three and Early Intervention transition procedures 1. The school district encourages referrals from the Department of Public Health, other agencies, and individuals for young children when or before the child turns two-and-one-half years old in order to ensure continuity of services and to ensure the development and implementation of an IEP for eligible children by the date of the child's third birthday in accordance with federal requirements. 2. The district implements procedures to ensure the effective transition of young children with disabilities from Early Intervention Programs through participation in transition planning conferences arranged by such programs. State Regulations 28.06(7)(b) Federal Requirements 34 CFR 300.24(b)(3); 300.121(c); 300.132; 300.342(c) District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard SE 18A IEP development and content 1. Upon determining that the student is eligible for special education, the Team, including the parent(s), develops an IEP at the Team meeting using the evaluation data to guide development of measurable, annual goals and objectives/benchmarks for the student. If the district chooses to draft any element(s) of the IEP for discussion, the Team Chairperson ensures that those elements are genuinely considered prior to adoption at the Team meeting. All ideas and needs of the child as expressed by all Team members, especially the parents, are genuinely considered by the district prior to proposing the IEP. 2. The IEP includes specially designed instruction to meet the needs of the individual student and related services that are necessary to allow the student to benefit from the specially designed instruction, or consists solely of related services that are necessary to allow the student to access the general curriculum, consistent with federal and state requirements. 3. In developing the IEP, the Team proposes specially designed instruction and related services according to the needs of the child and not according to the availability of such instruction or related services. 4. The IEP is completed addressing all elements of the most current IEP format provided by the Department of Education. Where applicable, the district includes in the IEP, or other notice to the parent, information regarding the implementation of any necessary restraint procedures for students as required under 603 CMR 46.00. Medford Public Schools Coordinated Program Review Final Report Page 35 of 152 CRITERION NUMBER Legal Standard 5. 6. 7. If the Team members are unable to agree on the IEP, the Team chairperson states the elements of the IEP proposed by the school district. The school district ensures that each IEP Team has at least one person with authority to commit the resources of the district and that whatever services are set out in the IEP will actually be provided and that the IEP will not be changed at a higher administrative level within the district. The IEP is written in generally understandable language. State Regulations Federal Requirements 28.05(3), (4), (6) and (7) 34 CFR 300.340-300.350; 300.343(a) 28.06(2) 34 CFR Part 300, Appendix A, Question #22. District Response Required: Yes Rating: Partially Implemented Department of Education Findings: The student record review shows that IEP goals and objectives at the preschool, elementary, middle school s and alternative schools are typically well-written, measurable and address the individual student’s area of educational need. However, at the high school level, including the vocational school, the goals and objectives are not always written in measurable terms, specific to the student’s disability(ies) and need for specialized instruction and/or therapeutic intervention. IEP Teams do not always fully describe the reasons why the student is being removed from the general education program. IEPs for students placed in the vocational school do not always contain goals for the vocational component of the student’s program, when necessary and appropriate. (Refer to finding under CTE 5.) IEPs for students, who have social-emotional and behavioral needs, do not always include individualized goals and/or a behavioral intervention plan to address the student’s documented needs. CRITERION NUMBER Legal Standard SE 18B Determination of placement; provision of IEP to parent 1. At the Team meeting, after the IEP has been fully developed, the Team determines the appropriate placement to deliver the services on the student’s IEP. 2. Unless the student’s IEP requires some other arrangement, the student is educated in the school that he or she would attend if the student did not require special education. 3. The decision regarding placement is based on the IEP, including the types of related services that are to be provided to the child, the type of settings in which those services are to be provided, the types of service providers, and the location at which the services are to be provided. 4. The placement selected by the Team is the least restrictive environment consistent with the needs of the student. Medford Public Schools Coordinated Program Review Final Report Page 36 of 152 CRITERION NUMBER Legal Standard 5. Immediately following the development of the IEP, and within 45 school working days after receipt of the parent’s written consent to an initial evaluation or reevaluation, the district provides the parent with two (2) copies of the proposed IEP and proposed placement along with the required notice, except that the proposal of placement may be delayed according to the provisions of 603 CMR 28.06(2)(e) in a limited number of cases. State Regulations 28.05(6) and (7) Rating: Partially Implemented Federal Requirements 34 CFR 300.346 District Response Required: Yes Department of Education Findings: Interviews and student records indicate that the vocational school does not always base the student’s services or program placement on the basis of the least restrictive environment, rather on the availability of personnel. In some cases, students’ placements were changed from a content area inclusion classroom to a resource room setting without a documented Team determination that the student’s lack of progress in the inclusion classroom required movement to a more restrictive setting rather than examine the student’s needs for supplementary aids , services and modifications.. In addition, interviews and student records indicate that some students in the vocational school have received instruction in general education mainstream English and Math classes with support, but not in other mainstream content area classes. The vocational school tends to place students on IEPs into resource rooms, which results in limited usage of the inclusion model as an option for placement. (Refer to finding under CTE 5.) CRITERION NUMBER Legal Standard SE 19 Extended evaluation If the Team finds a student eligible for special education and finds the evaluation information insufficient to develop a full or partial IEP, the Team, with the parents’ consent, agrees to an extended evaluation period. 1. The extended evaluation period is not used to deny programs or services determined to be necessary by the Team. If, prior to the extended evaluation, the Team determines that sufficient information is available to determine, in part, necessary annual goals and services, the Team writes a partial IEP that, if accepted by the parent, is immediately implemented by the district while the extended evaluation is occurring. 2. The extended evaluation period is not used to allow additional time to complete the required assessments. 3. If the parent consents to an extended evaluation, the Team documents their findings and determines what evaluation time period is necessary and the types of information needed to develop an IEP. The Team may decide to meet at Medford Public Schools Coordinated Program Review Final Report Page 37 of 152 CRITERION NUMBER Legal Standard intervals during the extended evaluation, but in all cases reconvenes promptly to develop an IEP when the evaluation is complete. 4. The extended evaluation may extend longer than one week, but does not exceed eight school weeks. 5. The extended evaluation is not considered a placement. State Regulations 28.05(2)(b) Rating: Partially Implemented Federal Requirements District Response Required: Yes Department of Education Findings: Student record review and interviews show that there is a lack of understanding and knowledge by IEP Teams regarding the appropriate implementation of an extended evaluation. In some cases, the extended evaluation is used as a diagnostic placement. CRITERION NUMBER Legal Standard SE 20 Least restrictive program selected 1. The program selected is the least restrictive environment for students, with consideration given to any potential harmful effect on the student or on the quality of services that he or she needs. 2. If the student is removed from the general education classroom at any time, the Team states why the removal is considered critical to the student’s program and the basis for its conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. 3. The district does not remove an eligible child from the general education classroom solely because of needed modification in the curriculum. 4. If a student’s IEP necessitates special education services in a day or residential facility or an out-of-district educational collaborative program, the IEP Team considers whether the student requires special education services and support to promote the student’s transition to placement in a less restrictive program. State Regulations 28.06(2)(a); Chapter 71B, section 3 Rating: Partially Implemented Federal Requirements 34 CFR 300.130; 300.550-300.556 District Response Required: Yes Department of Education Findings: Refer to the findings under SE 18B regarding placement of students in courses at the vocational school. Medford Public Schools Coordinated Program Review Final Report Page 38 of 152 CRITERION NUMBER Legal Standard SE 21 School day and school year requirements 1. The Team routinely considers the need for an educational program that is less than or more than the regular school day or school year, including extended day, or year, and/or residential services and indicates on the IEP why the shorter or longer program is necessary. 2. The daily duration of the child’s program is equal to that of the regular school day unless the Team states that a different duration is necessary to provide a free appropriate public education to the child. In such case the daily duration of the program shall be specified by the Team, and Team shall state on the IEP the reason for such different duration. 3. Specialized transportation schedules do not impede a student’s access to a full school day and program of instruction. 4. An extended day or year program is identified if the student has demonstrated or is likely to demonstrate substantial regression in his or her learning skills and/or substantial difficulty in relearning such skills if an extended program is not provided. 5. If residential services are required, the IEP clearly specifies the reasons for such determination and how such services will be coordinated with the day education services provided to the student. Additionally, the annual goals and services on the student’s IEP reflects the comprehensive nature of the educational program required. 6. Camping or recreation programs provided solely for recreational purposes and with no corresponding IEP goals or specially designed instruction are not to be considered for extended year programs. State Regulations 28.05(4) Chapter 69, Section 1G Rating: Implemented Federal Requirements 34 CFR 300.309(b) District Response Required: No CRITERION NUMBER Legal Standard SE 22 IEP implementation and availability 1. Where the IEP of the student in need of special education has been accepted in whole or in part by that student's parent, the school district provides the mutually agreed upon services without delay. 2. At the beginning of each school year, the district has an IEP in effect for each eligible student within its jurisdiction. 3. Each teacher and provider described in the IEP is informed of his or her specific responsibilities related to the implementation of the student’s IEP. Medford Public Schools Coordinated Program Review Final Report Page 39 of 152 CRITERION NUMBER Legal Standard 4. The school district does not delay implementation of the IEP due to lack of classroom space or personnel, provides as many of the services on the accepted IEP as possible and immediately informs parents in writing of any delayed services, reasons for delay, actions that the school district is taking to address the lack of space or personnel and offers alternative methods to meet the goals on the accepted IEP. Upon agreement of the parents, the school district implements alternative methods immediately until the lack of space or personnel issues are resolved. State Regulations 28.05(7)(b); 28.06(2)(d)(2) Rating: Partially Implemented Federal Requirements 34 CFR 300.342 District Response Required: Yes Department of Education Findings: Interviews and the review of student records show that, at the preschool and elementary level, there is a lack of oversight regarding the ongoing provision of related services. In a number of cases, when related services are interrupted due to the lack of personnel, the district does not implement the required procedures to immediately notify parents in writing of the interruption in services, the reason for the interruption in services and the steps the district will take to provide an alternative plan for the continuation of services and goals as agreed to on the student’s current IEP. At the high school level, regular education teaching staff are not always informed of their responsibilities for students on IEPs and Section 504 plans. In addition, there is no system in place to monitor the ongoing provision of IEP services, modifications and accommodations and Section 504 accommodations. (Refer to findings under CTE 12 for the Cooperative Education Program at the vocational school.) CRITERION NUMBER Legal Standard SE 23 Confidentiality of personally identifiable information The district protects the confidentiality of any personally identifiable information that is collected, used or maintained in accordance with federal and state law. State Regulations Federal Requirements 603 CMR 23.00 (Student Records Regulations) 34 CFR 300.560-576; Family Educational Rights and Privacy Act (FERPA) District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Interviews indicate that at the high school, evaluators are not always provided with appropriate spaces and adequate scheduling time when conducting assessments for initial and reevaluations. In some cases, evaluators use a classroom during free periods. This practice typically does not allow the evaluator to complete the testing and imposes further time constraints on the completion of the agreed upon evaluations as referenced in SE 1. Medford Public Schools Coordinated Program Review Final Report Page 40 of 152 CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION II. STUDENT IDENTIFICATION AND PLACEMENT Legal Standard MOA 1 Identification of limited-English-proficient students The district uses qualified staff and appropriate procedures and assessments to identify students who are limited-English-proficient and assess their level of English proficiency. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a),(b); EEOA: 20 U.S.C. 1703(f); 603 CMR 14.02; M.G.L c. 76, s. 5; 603 CMR 26.03 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to CTE 5 regarding the identification of students who are limited-English-proficient at the vocational school. CRITERION NUMBER Legal Standard MOA 2 Program modifications and support services for limited-English-proficient students The district implements necessary program modifications and support services to serve effectively limited-English-proficient students who need special language assistance. Such program modifications and support services: 1. are based on sound education theory; 2. provide for English-language development; 3. provide for the meaningful participation of limited-English-proficient students in the district’s educational program; 4. are evaluated and appropriately revised in an ongoing manner; and 5. are demonstrably useful in assisting students receiving such program modifications and services to gain English language proficiency. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a),(b); EEOA: 20 U.S.C. 1703(f); M.G.L. c. 71, s. 38Q1/2; 603 CMR 28.03(3)(a); M.G.L. c. 71A, ss. 2(e), 4; 603 CMR 14.04; M.G.L. c. 76, s. 5; 603 CMR 26.03 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 41 of 152 CRITERION NUMBER Legal Standard MOA 2A Identification of homeless children and youth The homeless education liaison designated under MOA 11A ensures that homeless children and youth are identified by school personnel and through coordination activities with other entities and agencies. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(i) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 2B Equal educational opportunity for homeless children and youth The homeless education liaison ensures that homeless children and youth enroll in, and have a full and equal opportunity to succeed in, district schools. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(ii) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 2C Access to services for homeless families, children, and youth The homeless education liaison ensures that homeless families, children, and youth receive educational services for which they are eligible, including Head Start and Even Start programs and preschool programs administered by the district, and referrals to health care services, dental services, mental health services, and other appropriate services. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(iii) Rating: Commendable District Response Required: No Department of Education Findings: Based on interviews and documentation, an exemplary level of procedures and referrals are in place that ensure that homeless children and youth enrolled in the schools receive all services for which they are eligible. The forms and information are available in different languages and additional translations are done as needed. There is a strong collaboration with the nurses, Board of Health, medical agencies and hospitals in providing health care to the homeless families in Medford. Medford Public Schools Coordinated Program Review Final Report Page 42 of 152 CRITERION NUMBER Legal Standard MOA 3 Access to a full range of education programs Students from linguistic, racial, and ethnic minorities; males; females; homeless students; and students with disabilities all have access equal to that of other students to the general education program and the full range of any occupational/vocational education programs offered by the district. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a),(b); EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.34, 106.35; Section 504: 29 U.S.C. 794; 34 CFR 104.4; Title II: 42 U.S.C. 12132; 28 CFR 35.130; IDEA: 34 CFR 300.305; NCLB: Title III, Part A, Sec. 3121(c)(1)(C); Title X, Part C, Secs. 721, 722(g)(4); Mass. Const. amend. art. 114; M.G.L. c. 71A, s. 7; c. 76, s. 5; 603 CMR 26.03 District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Refer to findings under CTE 4, CTE 8, CTE 9, and CTE 14 regarding limited access to technology and computer labs, the cooperative education program, guidance and counseling, advanced placement and honors courses and consistent, rigorous regular education curricular requirements for all students. At the high school, the science resource room does not have access to the lab facilities as part of the curriculum. Students placed in resource rooms at the middle school have limited technological access to tech and computer labs. CRITERION NUMBER Legal Standard MOA 4 Placement of disabled, linguistic and racial minority, homeless, and female/male students Patterns of placement in district programs and services for disabled students, linguistic and racial minority students, homeless students, and females are consistent with patterns of placement for non-disabled students, linguistic and racial majority students, nonhomeless students, and males. If these patterns of placement are not consistent, the district is able to demonstrate that placements have been made for valid educational reasons. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a),(b); EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.34, 106.35, 106.36; Section 504: 29 U.S.C. 794; 34 CFR 104.4; Title II: 42 U.S.C. 12132; 28 CFR 35.130; NCLB: Title III, Part A, Sec. 3121(c)(1)(C); Title X, Part C, Secs. 721, 722(g)(4); Mass. Const. amend. art. 114; M.G.L. c. 71A, s. 7; c. 71B, s. 6; c. 76, s. 5; 603 CMR 26.03 District Response Required: Yes Rating: Partially Implemented Medford Public Schools Coordinated Program Review Final Report Page 43 of 152 Department of Education Findings: Based upon the review of the DOE data submitted by the district for the 2003-04 school year, there were some categories of placement patterns for students with disabilities and limited English proficient students that are possible indicators of underrepresentation or overrepresentation. The data indicates the following possible trends: overrepresentation of African-American students in substantially separate classrooms; overrepresentation of African American and limited English proficient students in Title 1 programs; under-representation in advanced placement, Chapter74 and Non-chapter 74 programs; under-representation of students on IEPs at the middle school placed in full inclusion settings. The district has reviewed the above possible trends of disproportionality and has initiated a study group during the summer of 2005 for continued investigation and examination of the issues. CRITERION NUMBER Legal Standard MOA 5A Placement of homeless students According to the best interest of the homeless student, the district either 1. continues the student’s education in the student’s school of origin for the duration of homelessness and, if the student becomes permanently housed during an academic year, for the remainder of that academic year; or 2. enrolls the student in any public school that nonhomeless students who live in the attendance area where the student is actually living (with or without parents) are eligible to attend. If the district sends the student to a school other than the school of origin or a school requested by the student’s parent or guardian, it provides the parent or guardian with a written explanation, including a statement of the right to appeal the placement. If the student is an unaccompanied youth, notice of the right to appeal is provided to the student. NCLB: Title X, Part C, Sec. 722(g)(3)(A), (B) District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard MOA 5B Immediate enrollment of homeless students 1. The school where a homeless student is placed immediately enrolls the student even if he or she is unable to produce records normally required for enrollment, such as previous academic records, medical records, or proof of residency. 2. The enrolling school immediately contacts the school last attended by the homeless student to obtain relevant academic and other records. 3. If the homeless student needs to obtain immunizations or immunization or medical records, the enrolling school immediately refers the student’s parent Medford Public Schools Coordinated Program Review Final Report Page 44 of 152 CRITERION NUMBER Legal Standard or guardian (or the student, if an unaccompanied youth) to the homeless education liaison for assistance in obtaining them. NCLB: Title X, Part C, Sec. 722(g)(3)(C) District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard MOA 5C Transportation of homeless students to and from the school of origin 1. The school district has adopted policies and practices to ensure that transportation is provided, at the request of the parent or guardian (or in the case of an unaccompanied youth, the homeless education liaison), to and from the school of origin, in accordance with the following provisions. 2. If the homeless student is continuing to attend his or her school of origin and continues to live in the school district in which the school of origin is located, the student’s transportation to and from the school of origin is provided or arranged by the school district in which the school of origin is located. 3. If a homeless student is continuing to attend his or her school of origin but lives in another district than that in which the school of origin is located, the two districts agree on a method to apportion responsibility and costs for transportation to and from the school of origin. If they cannot agree on a method, the responsibility and costs are shared equally. NCLB: Title X, Part C, Sec. 722(g)(1)(J)(iii) District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard MOA 5D Disputes over the enrollment of homeless students If a dispute arises over a homeless student’s placement or enrollment in a school: 1. the school in which enrollment is sought immediately admits the homeless student, pending resolution of the dispute; 2. the school provides the parent or guardian of the student with a written explanation of the school’s decision regarding school selection or enrollment, including the rights of the parent, guardian, or unaccompanied youth to appeal the decision; Medford Public Schools Coordinated Program Review Final Report Page 45 of 152 CRITERION NUMBER Legal Standard 3. the student, parent, or guardian is referred to the homeless education liaison, who carries out the dispute resolution process prescribed by the Department of Education and, in the case of an unaccompanied youth, ensures that the youth is immediately enrolled in school pending resolution of the dispute. NCLB: Title X, Part C, Sec. 722(g)(3)(E) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 6 Availability of in-school programs for pregnant students 1. Pregnant students are permitted to remain in regular classes and participate in extracurricular activities with non-pregnant students throughout their pregnancy, and after giving birth are permitted to return to the same academic and extracurricular program as before the leave. 2. The district does not require a pregnant student to obtain the certification of a physician that the student is physically and emotionally able to continue in school unless it requires such certification for all students for other physical or emotional conditions requiring the attention of a physician. Title IX: 20 U.S.C. 1681; 34 CFR 106.40(b) District Response Required: Rating: Implemented CRITERION NUMBER No TITLE 1 II. STUDENT IDENTIFICATION AND PLACEMENT Legal Standard TI 19 (For Targeted Assistance Schools) A description is available of the multiple, objective, educationally-related criteria used to identify and rank eligible students in grade 3 and higher who are failing or most at-risk of failing to meet the high student academic performance and assessment standards required of all students. 1115 (b)(1)(B) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 46 of 152 CRITERION NUMBER Legal Standard TI 20 (For Targeted Assistance Schools) There is evidence that limited English proficient students, students with disabilities, and students who are homeless are identified as eligible and selected for Title I services on the same basis as other students selected to receive services. 1115(b)(2)(A) NCLB District Response Required: No Rating: Implemented CRITERION NUMBER CAREER AND TECHNICAL EDUCATION II. STUDENT IDENTIFICATION AND PLACEMENT Legal Standard CTE 4 Students enrolled in career and technical education programs are appropriately identified for services. Perkins Sections 3, 135, 315; Chapter 74 603 CMR 4.03 (4);(6);(7); Title IX. *Perkins definition of “career and technical education.” Career and technical education means organized educational activities that offer a sequence of courses that provides individuals with the academic and technical skills the individuals need to prepare for further education and for careers in current or emerging employment sectors. **Chapter 74 definition of “vocational technical education program.” A program approved by the Department that provides instruction in academic and technical subject matter and employability skills necessary for high wage/high demand occupations and further education. District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Students enrolled in career/vocational technical education programs are appropriately identified for services. Perkins Sections 3, 135, 315; Chapter 74 603 CMR 4.03(4);(6);(7); Title IX. Perkins and Chapter 74 Criteria Based upon record reviews and interviews with staff, parents/guardians and students, career/vocational technical students are not afforded the same support services as Medford High School (MHS) students. For example, there is no computer lab and few classrooms are equipped with functioning computers. Library materials for career/vocational technical students are identified with a blue dot, used to represent books for “reluctant” and “low-level” readers. Few students at Medford Vocational Technical High School (MVTHS) are provided with college counseling. The general attitude communicated by staff is that MVTHS students are “motivated to work, not go to college”. A limited number of CVTE programs provide on-site, work-based learning opportunities and support (e.g., Early Childhood and Construction). Few students participate in cooperative education and there is little evidence that programs promote off-site work-based learning opportunities. Based on interviews and documentation, counseling programs and interventions (e.g., college counseling, career planning) are not implemented according to a school-counseling curriculum. Medford Public Schools Coordinated Program Review Final Report Page 47 of 152 While the MVTHS handbook contains the required Title IX non-discrimination statement, one protected class (i.e., sexual orientation) is missing. In addition, the term “handicapped” as opposed to “disability” is used. CRITERION NUMBER Legal Standard CTE 5 Special population students are appropriately identified for services. Perkins Sections 135, 316; Chapter 74 603 CMR 4.03 (4)(d) Perkins identified special populations: individuals with disabilities individuals from economically disadvantaged families, including foster children individuals preparing for nontraditional by gender training and employment single parents, including single pregnant women displaced homemakers individuals with limited English proficiency (English language learners) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Special population students are appropriately identified for services. Perkins Sections 135, 316; Chapter 74 603 CMR 4.03(4)(d). Perkins and Chapter 74 Criteria: Based on record reviews and interviews, students with disabilities are identified for services; however, there is no evidence that the IEP team considers how the disability affects the students’ technical skill development, and the need for support services in technical shops, if necessary. Medford Vocational Technical High School (MVTHS) has 13 students identified as First Language Not English, as reported in SIMS data; however, there is no documentation of the assessment of their English proficiency or home language surveys. There is also no evidence that students with limited English proficiency, economically disadvantaged students or nontraditional by gender students are appropriately identified and receive support services at MVTHS. CRITERION NUMBER ENGLISH LEARNER EDUCATION II. STUDENT IDENTIFICATION AND PLACEMENT Legal Standard ELE 3 Initial Identification The district has procedures that actively seek to identify limited English proficient students. Medford Public Schools Coordinated Program Review Final Report Page 48 of 152 CRITERION NUMBER ENGLISH LEARNER EDUCATION II. STUDENT IDENTIFICATION AND PLACEMENT Legal Standard Authority: G.L. c. 71A § 4, 5 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard ELE 4 Waiver Procedures 1. Waivers may be granted based on parent request, providing the parent annually visits the school and provides written informed consent. Parents must be provided with program descriptions in a language they can understand. 2. Students who are under age 10, may only be granted waivers if (a) the student has been placed in an English language classroom for at least 30 calendar days, (b) the school certifies in no less than 250 words that the student “has special and individual physical or psychological needs, separate from lack of English proficiency” that requires an alternative program, and (c) the waiver is authorized by both the school superintendent and principal. All waiver requests and school district responses (approved or disapproved waivers) must be placed in the student’s permanent school record. For students under age 10, both the superintendent and the principal must authorize the waiver, and it must be made under guidelines established by, and subject to the review of the local school committee. These guidelines may, but are not required to, contain an appeals process. Students who are over age 10 may be granted waivers when it is the informed belief of the school principal and educational staff that an alternative program would be better for the student’s overall educational progress. Students receiving waivers may be transferred to other English language education programs. See 603 CMR 14.04. Authority: G.L. c. 71A, § 5 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Documentation shows that the district has knowledge of the required waiver procedures and have translated the waiver forms into Portuguese and Haitian-Creole. However, there is a lack of consistent understanding of the required procedures in order to implement the waiver option system-wide. The district tends to implement the procedures regarding a parent’s right to opt out, rather than the above waiver procedures Medford Public Schools Coordinated Program Review Final Report Page 49 of 152 CRITERION NUMBER Legal Standard ELE 5 Program Placement and Structure The district places LEP students in 1. “sheltered English immersion” classrooms, in which nearly all books and instructional materials are in English, but with the curriculum and presentation designed for students who are learning the language. All reading, writing and subject matter are taught in English. Teachers may use an English learner’s native language, when necessary, for clarification purposes. Districts may also modify general education classrooms, so that the activities and instruction in those classrooms provide sheltered English instruction to LEP students; or 2. “two-way bilingual” classrooms, in which students develop language proficiency in two languages by receiving instruction in English and another language in a classroom that is usually comprised of an equal number of proficient English speakers and proficient speakers of the other language; or 3. (for kindergarten students) either a sheltered English immersion, twoway bilingual, or an English-only language general education classroom with assistance in English language acquisition, including, but not limited to, English as a second language. Authority G.L. c. 71A, § 2, 4, 7; Title VI District Response Required: Rating: Partially Implemented Yes Department of Education Findings: The district has English language support programs in place for students from grades 1-12. However, interviews indicate that the district has not developed a program to provide English language support to kindergarten students who are limited English proficient, consistent with the requirements of Chapter 71A and Title VI. At the high school and at the vocational school, LEP students are not always provided with sheltered English instruction in elective and nonacademic classes and in the vocational program. (Refer to CTE 14.) Medford Public Schools Coordinated Program Review Final Report Page 50 of 152 CRITERION NUMBER Legal Standard ELE 6 Program Exit and Readiness 1. The district does not re-designate a student from Limited English Proficient (LEP) to Formerly Limited English Proficient (FLEP), until: a) s/he is deemed English proficient; and b) can participate meaningfully in all aspects of the district’s general education program without the use of adapted or simplified English materials. 2. The time in which LEP students receive sheltered English immersion instruction is not normally intended to exceed one school year. 3. Districts may not limit or cap the amount of time in which an LEP student is placed in a language support program and may only exit the student from such a program after determining that the student is proficient in English. Authority: Title VI; G.L. c. 71A, § 4 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Documentation shows that there are stated measurable thresholds for determining a student’s’ ability to exit an English language support program, and procedures to monitor students redesignated as Formerly Limited English Proficient (FLEP). However, interviews and student records indicate that no formalized procedures are in place to re-designate LEP students to a FLEP status to ensure consistent implementation of the requirements system-wide. In addition, interviews and student records indicate that there are no formal exit criteria in place to assess and move limited English proficient students at appropriate junctures, who are placed in SEI classrooms and have attained the necessary English language proficiency level and skill ability level. Medford Public Schools Coordinated Program Review Final Report Page 51 of 152 COMPONENT III: PARENTAL INVOLVEMENT The criteria in this component examine whether the district has ensured that parents are notified, in the appropriate language, and are involved in decisions regarding their children’s programs and services for the program areas listed below: Special Education (Report Issues # SE 24-32) Civil Rights Methods of Administration (Report Issue # MOA 6A-7) Title I (Report Issues # TI 21-23) Safe and Drug Free Schools (Report Issues # SDF 1-3) Career and Technical Education (Report Issues # CTE 6-7) English Learner Education (Report Issue # ELE 7) Medford Public Schools Coordinated Program Review Final Report Page 52 of 152 SPECIAL EDUCATION III. PARENTAL INVOLVEMENT CRITERION NUMBER Legal Standard SE 24 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE 1. A student may be referred for an evaluation by a parent or any person in a caregiving or professional position concerned with the student's development. 2. When a student is referred for an evaluation to determine eligibility for special education, the school district sends written notice to the child's parent(s) within 5 school days of receipt of the referral. 3. Notice is given by the district within a reasonable time for all other actions. 4. The school district provides the student's parent(s) with an opportunity to consult with the Special Education Administrator or his/her designee to discuss the reasons for the referral and the nature of the proposed evaluation 5. The district provides parents with an opportunity to consult with the Administrator of Special Education or his/her designee regarding the evaluators to be used and the proposed content of all required and optional assessments 6. The school district does not limit a parent’s right to refer a student for timely special education evaluation because the district has not fully explored and/or attempted some or all of the available instructional support programs or other interventions available in general education that may be described in the district’s Curriculum Accommodation Plan, including any pre-referral program. 7. The school district refuses to conduct an initial evaluation only when the circumstances of a student make clear that there is no suspicion of a disability and that there is no concern about the student’s development. State Regulations 28.04(1) Rating: Partially Implemented Federal Requirements 34 CFR 300.503(a) District Response Required: Yes Department of Education Findings: Student record review indicates that there is a wide variance in the completion of the required content in the written notices (N1/N2). The out-of-district written notices were very detailed and responded to each of the questions, whereas in-district notices do not always sufficiently address the required questions or fully present the district’s proposal or refusal to act. Medford Public Schools Coordinated Program Review Final Report Page 53 of 152 CRITERION NUMBER Legal Standard SE 25 Parental consent In accordance with state and federal law, the school district obtains informed parental consent as follows: 1. The school district obtains written parental consent before conducting an initial evaluation and before making an initial placement of a student in a special education program. Written parental consent is obtained before conducting a reevaluation and before placing a student in a special education placement subsequent to the initial placement in special education. 2. The school district obtains consent before initiating extended evaluation services. 3. The school district obtains consent to the services proposed on a student’s IEP before providing such services.. 4. A parent is informed that consent may be revoked at any time. Except for initial evaluation and initial placement, consent may not be required as condition of any benefit to the child. 5. When the participation or consent of the parent is required and the parent fails or refuses to participate, the attempts to secure the consent of the parent are implemented through multiple attempts using a variety of methods which are documented by the district. Such efforts may include letters, written notices sent by certified mail, electronic mail (e-mail), telephone calls, or, if appropriate, TTY communications to the home, and home visits at such time as the parent is likely to be home. Efforts may include seeking assistance from a community service agency to secure parental participation. 6. If, subsequent to initial evaluation and initial placement and after following the procedures required by the regulations, the school district is unable to obtain parental consent to a reevaluation or to placement in a special education program subsequent to the initial placement, or the parent revokes consent to such reevaluation or placement, the school district considers with the parent whether such action will result in the denial of a free appropriate public education to the child. If, after consideration, the school district determines that the parent’s failure or refusal to consent will result in a denial of a free appropriate public education to the student, it seeks resolution of the dispute through Special Education Appeals State Regulations 28.07(1) Rating: Implemented Medford Public Schools Coordinated Program Review Final Report Federal Requirements 34 CFR 300.500(b)(1) District Response Required: No Page 54 of 152 CRITERION NUMBER Legal Standard SE 26 Parent participation in meetings 1. The district ensures that one or both parents of a child are members of any group that makes decisions on the educational placement of their child. 2. The Administrator of Special Education notifies parent(s) in writing of any Team meeting early enough to ensure that they have an opportunity to attend. 3. The district schedules the meeting at a mutually agreed upon time and place; and documents such efforts. 4. If neither parent can attend, the district uses other methods to ensure parent participation, including individual or conference telephone calls, or video conferencing. 5. In cases where the district, after reasonable efforts, is unable to obtain the parents’ participation in Team meeting discussions and decisions, the district conducts the Team meeting and documents its attempts to facilitate the parents’ participation. State Regulations 28.02(22) Rating: Implemented Federal Requirements 34 CFR 300.345(d), 300.501 District Response Required: No CRITERION NUMBER Legal Standard SE 27 Content of Team meeting notice to parents 1. The parent notice of an evaluation required by 603 CMR 28.04(1)(a) meets all of the content requirements set forth in M.G.L. c.71B, §3, and in federal law and seeks the consent of the parent for any evaluation to occur, and provides the parent with the opportunity to express any concerns or provide information on the student’s skills or abilities and to consult regarding the evaluators to be used. 2. The parent notice of any Team meeting states the purpose, time and location of the meeting as well as who will be in attendance. State Regulations 28.04(1)(b) Rating: Implemented Medford Public Schools Coordinated Program Review Final Report Federal Requirements 34 CFR 300.503-504 District Response Required: No Page 55 of 152 CRITERION NUMBER Legal Standard SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights Immediately following the development of the IEP and without undue delay, the district provides the parents with two copies of the proposed IEP or a written explanation of the finding of no eligibility for special education together with the required notice of procedural safeguards and parents’ rights. State Regulations 28.05(7) Rating: Partially Implemented Federal Requirements 34 CFR 300.345(f) District Response Required: Yes Department of Education Findings: Interviews indicate that when a parent is not provided with a proposed IEP at the conclusion of the Team meeting, the type of documentation provided to the parent is not consistent among Team chairpersons and is, sometimes, only the service delivery grid. Interviews indicate that parents were not always receiving the agreed upon goals, service delivery grid and a written summation of the main points of the meeting, if the proposed IEP is not provided to them at the conclusion of the Team meeting. CRITERION NUMBER Legal Standard SE 29 Communications are in English and primary language of home 1. Communications with parents are in simple and commonly understood words and are in both English and the primary language of the home if such primary language is other than English. Any interpreter used in fulfilling these requirements is fluent in the primary language of the home and familiar with special education procedures, programs and services. If the parents or the student are unable to read in any language or are blind or deaf, communications required by these regulations are made orally in English with the use of a foreign language interpreter, in Braille, in sign language, via TTY, or in writing, whichever is appropriate, and that all such communications are documented. 2. If the district provides notices orally or in some other mode of communication that is not written language, the district keeps written documentation (1) that it has provided such notice in an alternate manner, (2) that the content of the notice and (3) the steps taken to ensure that the parent understands the content of the notice. Medford Public Schools Coordinated Program Review Final Report Page 56 of 152 CRITERION NUMBER Legal Standard State Regulations 28.07(8) Rating: Partially Implemented Federal Requirements 34 CFR 300.345(e) District Response Required: Yes Department of Education Findings: Based upon student record reviews and interviews, the district demonstrates inconsistency regarding the translation of the mandated IEP documents throughout the evaluation and IEP process into the primary language of the parent/guardian. There is no documentation as to whether a parent/guardian needs language assistance or the type of assistance that is necessary to ensure access to the full IEP process. Interviews indicate that the district does not have a formal mechanism in place to document and update the primary language of the home and make a determination each school year as to the type of language assistance that parents, whose language is other than English, require for the purposes of written and oral communications. Staff do not always have current information as to the parents’ needs for language assistance, interpreters and translated documents when students move from level to level, such as elementary to middle and middle to high school. CRITERION NUMBER Legal Standard SE 30 Elements of notice of parents’ rights The district’s notice of parental rights contains all required elements included in the most current version of the Massachusetts Parent’s Rights Brochure. State Regulations M.G.L. c. 71B, Section 3 Rating: Implemented Federal Requirements 34 CFR 300.503-504 District Response Required: No CRITERION NUMBER Legal Standard SE 31 State and district responsibility for educational surrogate parents 1. When a student is without parental representation and requires an educational surrogate parent to be appointed in accordance with federal law and regulations, upon request of the Department, the district responsible for services to the student assists in identifying a person willing to serve as an educational surrogate parent. Medford Public Schools Coordinated Program Review Final Report Page 57 of 152 CRITERION NUMBER Legal Standard 2. Upon assignment by the Department, such educational surrogate parent has all the rights and responsibilities of a parent in making decisions regarding eligibility and services for special education for the assigned student. The Department provides notice of appointment to the school district and any state agency with custody of the student. 3. A person identified by the district and willing to serve as an educational surrogate parent has no conflict of interest and is not in the employ of the school district or any state or local agencies involved with the care of the student . 4. A person identified by the district, appointed by the Department, and serving as an educational surrogate parent does not receive financial remuneration from the district except that the school district reimburses the person for reasonable expenses related to the exercise of his or her responsibilities as an educational surrogate parent for a student enrolled in the district. State Regulations 28.07(7) Rating: Implemented Federal Requirements 34 CFR 300.515 District Response Required: No CRITERION NUMBER Legal Standard SE 32 Parent advisory council for special education 1. The school district has established a district-wide parent advisory council on special education. 2. Membership on the council is offered to all parents of children with disabilities and other interested parties. 3. The parent advisory council duties include but are not limited to: advising the district on matters that pertain to the education and safety of students with disabilities; meeting regularly with school officials to participate in the planning, development, and evaluation of the school district’s special education programs. 4. The parent advisory council has established by-laws regarding officers and operational procedures. 5. The parent advisory council receives assistance from the school committee without charge, upon reasonable notice, and subject to the availability of staff and resources. 6. The school district conducts, in cooperation with the parent advisory council, at least one workshop annually within the district on the rights of students and their parents and guardians under the state and federal special education laws and makes written materials explaining such rights available upon request. State Regulations Chapter 71B, Section 3; 28.07(4) Federal Requirements Medford Public Schools Coordinated Program Review Final Report Page 58 of 152 CRITERION NUMBER Legal Standard District Response Required: Rating: Partially Implemented Yes Department of Education Findings: Documentation and interviews indicate that the district and PAC are seeking to reorganize in order to demonstrate compliance with the standards of state regulation. The current PAC leadership and the district have not effectively worked together to ensure that workshops are conducted annually and that the PAC maintains an advisory position that is representative of all of the parents of special education children and students system-wide, rather than a small group of individual parents that are advocating for the needs of a select group of students and families. CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION III. PARENTAL INVOLVEMENT Legal Standard MOA 6A Information and opportunities for participation for parents and guardians of homeless students The homeless education liaison ensures that parents and guardians of homeless students are informed of the educational and related opportunities available to their children and are provided with meaningful opportunities to participate in their children’s education. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(iv) District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard MOA 6B Public notice of educational rights of homeless children and youth The homeless education liaison ensures that public notice of the educational rights of homeless children and youth is disseminated in places where they receive services, such as schools, family shelters, and soup kitchens. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(v) Rating: Commendable District Response Required: No Department of Education Findings: Based on interviews, documentation and site visits, Medford has done an exemplary job disseminating the public notice of educational rights of homeless children and youth. This information is available in seven languages and is posted in all schools, Indigo House, City Hall, Libraries, St. Raphael and St. Francis Food Pantries, Tri-City, religious institutions, parent information center, Family Life Shelter, health and community agencies and the city web site. Medford Public Schools Coordinated Program Review Final Report Page 59 of 152 CRITERION NUMBER Legal Standard MOA 6C Information and assistance with respect to transportation of homeless students The homeless education liaison ensures that each homeless student’s parent or guardian, as well as any unaccompanied youth, is fully informed of all transportation services, including transportation to and from the school of origin as required in MOA 5C above, and is assisted in accessing transportation to the school where the student is placed. NCLB: Title X, Part C, Sec. 722(g)(6)(A)(vii) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 6D Coordination and collaboration by the homeless education liaison The homeless education liaison coordinates and collaborates with state coordinators and community and school personnel responsible for the provision of education and related services to homeless children and youth. NCLB: Title X, Part C, Sec. 722(g)(6)(C) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 7 Information to be translated into languages other than English When students have parents or guardians with limited English language skills, general announcements and notices of extracurricular activities and other opportunities are distributed to them in the primary language of the home. When persons with limited English language skills reside in the community, school and program recruitment and promotional materials are disseminated to them in their primary language(s). Title VI; EEOA: 20 U.S.C. 1703(f); M.G.L. c. 76, s. 5; 603 CMR 26.02(2) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to finding under SE 29. Medford Public Schools Coordinated Program Review Final Report Page 60 of 152 CRITERION NUMBER TITLE 1 III. PARENTAL AND COMMUNITY INVOLVEMENT Legal Standard TI 21 School District Requirements: 1. Title I policies, programs, activities, and procedures are assessed for needs, planned, implemented and evaluated with meaningful consultation of parents of participating children. 1118(a)(1) 2. The district’s written parental involvement policy is developed and annually reevaluated with, agreed upon, and distributed to parents of participating children. 1118(a)(2) 3. The district provides coordination, technical assistance, and other resources to assist schools in planning and implementing effective parental involvement activities to improve student achievement and school performance. 1118(e)(2) NCLB 4. The district builds schools’ and parents’ capacity for strong parental involvement. 5. Title I parental involvement services are integrated with other programs’ parental involvement strategies at the school and district level. 6. The district conducts, with involvement of parents, an annual evaluation of the content and effectiveness of the parental involvement policy in improving student achievement and parental involvement. Evaluation results are used to improve programs and services. 1118(a)(2)(A) – (G) 7. The district has a system for schools to provide parents with “right to know” information: a. Status of school identified for school improvement b. Notice of teacher qualifications and right of parent to inquire c. Notice, if applicable, that students are taught by non- highly qualified teachers for more than four weeks. 1118(d)(3)(B) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Review of documentation and interviews indicate that the school district has not complied with the following requirement of this standard: #5) The district’s parent involvement activities are not integrated with other programs. CRITERION NUMBER Legal Standard TI 22 The district and schools provide materials and training to Title I parents to enable them to improve their children’s achievement (e.g., literacy training, using technology to foster parental involvement, frequent meetings with teachers, etc.). 1118(e)(2) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 61 of 152 CRITERION NUMBER Legal Standard TI 23 School Requirements: 1. The school has a written parent involvement policy that is developed jointly with, agreed upon, and distributed to parents of participating children. 1118(b)(1) NCLB 2. Parents are notified of the school’s Title I parent involvement policy in an understandable format. To the extent practicable, this information is provided in the language of the home. 1118(b)(1) NCLB 3. The school implements the following parent involvement requirements: a. Convenes an annual informational meeting at a time convenient for parents; b. Provides parents with opportunities for regular meetings regarding the education of their children; and offers a flexible number of meetings (e.g., in the early morning or in the evening, etc.); c. Involves parents in an organized, ongoing, timely way in the planning, review, and improvement of school parental involvement policy and schoolwide programs; d. Provides parents with timely information about Title I programs, descriptions, and an explanation of the Title I curriculum and assessment procedures; and e. Provides parents with materials and training to improve their children’s achievement. 1118 (c)(1)-(4); 1118 (e)(2) NCLB 4. Each school develops jointly with parents a School-Parent Compact that outlines shared responsibilities for improving student achievement and achieving the state’s high standards. 1118(d) NCLB District Response Required: Rating: Implemented CRITERION NUMBER No SAFE AND DRUG FREE SCHOOLS III. PARENTAL INVOLVEMENT Legal Standard SDF 1 The Safe and Drug Free Schools program develops its application through timely and meaningful consultation with community agencies, parents, students and representatives from the schools and prevention community. [Title IV Sec. 4115 (b) (2) (E)] Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 62 of 152 CRITERION NUMBER Legal Standard SDF 2 The local education agency coordinates such agency’s programs and projects with community-wide efforts to achieve SEA’s goals for drug and violence prevention. [NCLB Title IV Sec. 4114 (c) (1) (B)] District Response Required: Rating: Commendable No Department of Education Findings: Based on interviews and documentation, Medford Public Schools participates at an exemplary level with other agencies in activities that include student, parent and teacher surveys, focus groups, program development and implementation, writing grants, evaluation and meetings regarding the prevalence of drugs and violence in the community. The community agencies are informed and participate in many meetings providing timely and meaningful consultation on the district’s drug and violence activities. Community agencies/people involved include, but are not limited to the following: Mayor Michael McGlynn, Medford Health Matters, Police and Fire Departments, Board of Health, Project Alliance, Office of Diversity, religious leaders, Tri-City Mental Health, Medford Alliance, Lawrence Memorial Hospital, District Attorney’s Office, Tufts University, Greater Lawrence Family Health Center, Medford Family Network and the Medford Housing Authority. Some examples of effective collaboration are: Community wide grants from Medford Health Matters and a policing grant implementing programs on drug, alcohol and violence prevention programs with activities for students and parents in the schools. As an extension of the drug prevention initiatives, the SDFS Coordinator collaborated with many organizations and groups in the Mock Car Accident program. This provided a realistic presentation on the consequences of drinking and driving, which was, followed by discussion in the classrooms. Project Safeguard provided DITEP training for school staff, chemical awareness sessions for parents and students and strengthened Drug and Alcohol Policies, existing programs, and access to emerging needs to achieve Medford’s goal of “Safeguard our Children and Youth, Safeguard Our Homes, Safeguard our Schools and Safeguard our Community”. The Police Department provided several trainings/presentations for parents and students. CRITERION NUMBER Legal Standard SDF 2A The local education agency coordinates such agency’s programs and projects with other federal, state and local programs for drug-abuse and violence prevention. [Title IV Sec. 4114 (c) (1) (B)] Rating: Commendable District Response Required: No Department of Education Findings: Based on interviews, documentation and observation, it is evident that Medford has an exemplary partnership in collaboration with local agencies implementing local, federal and state programs for Medford Public Schools Coordinated Program Review Final Report Page 63 of 152 drug-abuse and violence prevention for the schools and community. Examples include: Tobacco Cessation intervention supported by the Department of Public Health enhanced school health services grant; the Mental Health grant providing Second Step curriculum to preK-3 and training for parents; the SAMHSA grant through Medford Health Matters providing programs for parents, administration of the Community that Cares survey for students, and the data analysis; Tri-City Mental Health provides an outpatient drug counselor at Medford High School; and in coordination with the police department, 2 grants awarded from the Governor’s Highway Safety Bureau. CRITERION NUMBER Legal Standard SDF 3 There are program activities implemented to promote the involvement of parents. [Title IV Sec. 4116 (a) (1)] Rating: Implemented CRITERION NUMBER District Response Required: No CAREER AND TECHNICAL EDUCATION III. PARENT AND COMMUNITY INVOLVEMENT Legal Standard CTE 6 Parents/guardians, students, teachers, representatives of business and industry, labor organizations, postsecondary institutions, advisory committees and/or school councils, representatives of special populations, and other interested individuals are involved in the development, implementation, and evaluation of career and technical programs. Perkins Section.135; Chapter.74 Section 6, 603 CMR 4.03 (3) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Parents/guardians, students, teachers, representatives of business and industry, labor organizations, post secondary institutions, advisory committees and/or school councils, representatives of special populations, and other interested individuals are involved with the development, implementation, and evaluation of career/vocational technical education programs. Perkins Section 135; Chapter 74 Section 6, 603 CMR 4.03 (3) Perkins and Chapter 74 Criteria: Based on documentation and interviews, there is little evidence of involvement in the development, implementation, and evaluation of career/vocational technical education programs. Not all program advisory committees have acquired appropriate representation. In addition, the School Council responsible for the development of the school improvement plan for both Medford High and Medford Vocational Technical High School reportedly does not include representation from MVTHS. Medford Public Schools Coordinated Program Review Final Report Page 64 of 152 CRITERION NUMBER Legal Standard CTE 7 Appropriate information concerning career and technical education programs is provided to students and to their parents/guardians at least once a year before students enter the programs, and in no case later than the beginning of the ninth grade. Such information shall include: (a) the opportunities available in career and technical education; (b) eligibility requirements for enrollment in career and technical programs; (c) specific courses that are available; (d) employment and/or further education opportunities; and (e) placement Perkins Section. 135; Chapter.74 603 CMR 4.03 (4) (a)(b); (6); (7) District Response Required: Rating: Partially Implemented Yes Department of Education Findings: Appropriate information concerning career/vocational technical education programs is provided to students and to their parents/guardians at least once a year before students enter the program and in no case later than the beginning of ninth grade. Such information shall include: i) the opportunities available in career/vocational technical education; ii) eligibility requirements for enrollment in career/vocational technical programs; iii) specific courses that are available; iv) employment and/or further education opportunities; and v) placement Perkins Section 135; Chapter 74 603 CMR 4.03 (4 (a)(b;(6);(7) Perkins and Chapter 74 Criteria: Based on record reviews and interviews with staff and students, information concerning career/vocational technical education programs is not provided to students and their parents/guardians in languages other than English. Further, there is no written plan to address this concern. ENGLISH LEARNER EDUCATION III. PARENTAL INVOLVEMENT CRITERION NUMBER Legal Standard ELE 7 Parent Involvement The district develops a mechanism for including parents or guardians of LEP students in matters pertaining to their children’s education. Authority: Title VI Medford Public Schools Coordinated Program Review Final Report Page 65 of 152 CRITERION NUMBER ENGLISH LEARNER EDUCATION III. PARENTAL INVOLVEMENT Legal Standard Rating: Partially Implemented District Response Required: Yes Department of Education Findings: There is currently no formal mechanism in place to provide outreach to involve parents or guardians of LEP students in matters pertaining to their children’s education throughout the school year. In addition, there is no formal system in place to provide interpreters to translate for parent, who require language assistance to access and participate in parent activities and parent groups. Medford Public Schools Coordinated Program Review Final Report Page 66 of 152 COMPONENT IV: CURRICULUM AND INSTRUCTION The criteria in this component examine whether the district holds all students to high expectations and standards and ensures that the program areas reviewed are designed to maximize student performance within regular education and are implemented according to specific regulatory requirements with respect to learning time, class size, staffing ratio, and age spans. The criteria also examine if the district has provided for coordination across the following program areas: Special Education (Report Issues # SE 33-42) Civil Rights Methods of Administration (Report Issues MOA 7A-9) Title I (Report Issues # TI 24-28) Safe and Drug Free Schools (Report Issue # SDF 4) Career and Technical Education (Report Issues # CTE 8-14) English Learner Education (Report Issues #8-10) Medford Public Schools Coordinated Program Review Final Report Page 67 of 152 SPECIAL EDUCATION IV. CURRICULUM AND INSTRUCTION CRITERION NUMBER Legal Standard SE 33 Involvement in the general curriculum 1. District personnel reflect a full understanding of the connection between the Massachusetts Curriculum Frameworks and the expectations of the state for student performance as well as the rights of students with disabilities to be full participants in the general curriculum. 2. The district has either aligned its district curriculum with the Frameworks or has taken steps to provide students (including all students with disabilities) with essential learning opportunities that prepare the students to reach the state graduation standards. 3. At least one member of all IEP Teams is familiar with the general curriculum and is able to discuss an eligible student’s appropriate access to the general curriculum. 4. In the IEP the district documents the student’s participation in the general curriculum. State Regulations 28.05(4)(a) and (b) Rating: Partially Implemented Federal Requirements 34 CFR 300.347(a)(1)(i); 300.137 District Response Required: Yes Department of Education Findings: Interviews indicate that at the middle and high school levels, students placed in resource rooms do not always have the same access to scheduled classes in the computer labs and/or tech labs. At the vocational school, interviews indicate that for some students on IEPs, who require Wilson reading, those services are being provided during their English classes, rather than as a direct service. CRITERION NUMBER Legal Standard SE 34 Continuum of alternative services and placements The district provides or arranges for the provision of each of the elements of the IEPs of students in need of special education from the ages of three through twenty-one, ensuring that a continuum of services and alternative placements is available to meet the needs of all students with disabilities, and takes all steps necessary to ensure compliance with all elements of the IEPs, including vocational education. State Regulations Rating: Implemented Medford Public Schools Coordinated Program Review Final Report Federal Requirements 34 CFR 300.551;300.305; 300.123 District Response Required: No Page 68 of 152 CRITERION NUMBER Legal Standard SE 35 Specialized materials and assistive technology 1. Specialized materials and equipment specified in IEPs are provided, are of good quality and are suitable for the role they play in the IEP. 2. The school district provides evidence that assistive technology is considered for each eligible student and, if necessary, described in the IEP and provided by the district. State Regulations Federal Requirements 34 CFR 300.308, 34 CFR 300.346 District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Student record review and interviews indicate that IEP Teams do not always consider the student’s need for assistive technology materials or equipment. Staff lack knowledge regarding the availability of assistive technology resources and materials within the district, as well as the type of assistive technology materials and equipment to recommend for students to increase their access to the curriculum. * CRITERION NUMBER Legal Standard SE 36 IEP implementation, accountability and financial responsibility 1. The district ensures that IEPs are implemented without delay upon parent consent. 2. The district oversees in an ongoing manner the full implementation of each in-district and each out-of-district IEP it proposes which has been consented to by a child’s parents. 3. The district makes a good faith effort to assist the child to achieve the goals and objectives or benchmarks listed in the IEP. 4. The district provides all programs and services without expense to the child’s parents. 5. Each time the school district proposes to access the parent’s private insurance to support the costs of IEP implementation, the school district obtains the parent’s consent and informs the parents that their refusal to permit the school district to access their private insurance does not relieve the district of its responsibility to ensure that all required services are provided at no cost to the parents. State Regulations 28.06(3) Rating: Implemented Medford Public Schools Coordinated Program Review Final Report Federal Requirements 34 CFR 300.142; 300.350 District Response Required: No Page 69 of 152 CRITERION NUMBER Legal Standard SE 37 Procedures for approved and unapproved out-of-district placements 1. Individual student program oversight: The school district monitors the provision of services to and the programs of individual students placed in public and private out-of-district programs. Documentation of monitoring plans and all actual monitoring are placed in the files of every eligible student who has been placed out-of-district. To the extent that this monitoring requires site visits, such site visits are documented and placed in the students’ files for review. The duty to monitor out-of-district placements is not delegated to parents or their agents, to the Department of Education, or to the out-of-district placement. 2. Student right to full procedural protections: The school district retains full responsibility for ensuring that the student is receiving all special education and related services in the student's IEP, as well as all procedural protections of law and regulation. Any Team meetings conducted during the time that a student is enrolled in the out-of-district program are initiated by the school district in coordination with the out-of-district placement. 3. Preference to approved programs: The school district, in all circumstances, first seeks to place a student in a program approved by the Department pursuant to the requirements of 603 CMR 28.09. Preference is also given to approved programs located within the Commonwealth of Massachusetts if the choice of such program is consistent with the needs of the student and the choice of such program complies with LRE requirements. When an approved program is available to provide the services on the IEP, the district makes such placement in the approved program in preference to any program not approved by the Department. 4. Written contracts: The school district enters into written contracts with all public and private out-of-district placements. At a minimum, such contracts meet the content requirements of 28.06(3)(f)(1-5). 5. Use of unapproved programs: A school district that places a student in a program that has not been approved by the Department according to the requirements under 603 CMR 28.09 ensures that such programs and services are provided in appropriate settings by appropriately credentialed staff able to deliver the services on the student’s IEP. Students placed by the school district in such programs are entitled to the full protections of state and federal special education law and regulation. 6. Placement documentation: The following documentation is maintained by the school district pursuant to its placement of children in unapproved out-of-district programs: a. Search: The Administrator of Special Education documents the search for and unavailability of a program approved by the Department. The Administrator places such documentation in the student record. b. Evaluation of facility: The Administrator of Special Education or his/her designee thoroughly evaluates the appropriateness of any unapproved facility prior to placement of the student in such program. Such evaluation determines whether the unapproved facility can appropriately implement the student’s IEP in a safe and educationally Medford Public Schools Coordinated Program Review Final Report Page 70 of 152 CRITERION NUMBER Legal Standard c. d. e. f. appropriate environment. Such evaluation additionally determines whether the unapproved facility can and will provide the student with all the rights that are accorded to the student under state and federal special education law. Such evaluation is documented in detail and placed in the student record for review. To the extent that this evaluation requires a site visit, such site visits are documented and placed in the student record for review. The duty to evaluate the appropriateness of any unapproved facility is not delegated to the parents or their agents or the proposed unapproved facility. School district approval to operate a private school in Massachusetts: If services in an unapproved program are provided in a school setting, the Administrator of Special Education ensures that such school has received approval from the local school committee under M.G.L. c.76, §1 and a copy of such approval is retained in the student record. Pricing: Pursuant to the requirements for Compliance, Reporting and Auditing for Human and Social Services at 808 CMR 1.00, the Administrator obtains pricing forms required to set program prices for programs receiving publicly funded students. Such pricing forms are completed by the proposed placement and document that the price proposed for the student’s tuition is the lowest price charged for similar services to any student in that program. Notification of the Department of Education: Prior to placement, if the Team determines that placement in such facility is appropriate, the Administrator notifies the Department of the intent to place the student and the name and location of the proposed placement. In addition, the Administrator forwards the notice of proposed placement and completed pricing forms to the Department along with the information on the proposed terms of the contract that will govern such placement and documentation of a monitoring plan pursuant to 603 CMR 28.06(3)(b). The district maintains any documentation of the Department’s objections to such placement and the steps the district has taken in regard to such objection. The district maintains documentation of the approved price for publicly funded students as set by the state agency responsible for setting program prices. Out of state programs: If out-of-district programs are provided in a placement outside of Massachusetts, and such school has not received approval by the Department under 603 CMR 28.09, the Administrator of Special Education ensures that such school has received approval from the host state. State Regulations 28.02(14), 28.06(3) Rating: Commendable Medford Public Schools Coordinated Program Review Final Report Federal Requirements 34 CFR 300.2(c) District Response Required: No Page 71 of 152 Department of Education Findings: Based upon interviews and student record review, the district demonstrates excellent practices in the oversight and monitoring of the IEP process and procedures for students placed in out-of-district placements. The monitoring plans, progress reports and IEPs are detailed, specific to the student’s area of educational and/or therapeutic need and rate of progress. There is documented evidence of the district’s continual attention to the student’s out-of-district services and programs and to the possible timelines for the engagement of transition activities to bring students back into the district’s programs. CRITERION NUMBER Legal Standard SE 38 Educational services in institutional settings (ESIS) Department of Education responsibility: In cases where the Department provides certain special education services to eligible students in certain facilities operated by or under contract with the Department of Mental Health, the Department of Youth Services, County Houses of Corrections, or the Department of Public Health, the Department retains the discretion to determine, based upon resources, the type and amount of special education and related services that it provides in such facilities. School district responsibility: 1. The district implements its responsibilities to students in institutional settings by acting on requests for evaluation, issuing proposed IEPs in a timely manner, and providing special education and/or related services in accordance with state and federal law. 2. Where a student's IEP requires a type or amount of service that the facility does not provide, it remains the responsibility of the parent’s school district to implement the student's IEP by arranging and paying for the provision of such service(s). 3. The parent’s school district coordinates with the state agency to ensure that the student receives an evaluation, an annual review, and special education services as identified at a Team meeting convened by the parent’s school district. State Regulations 28.06(9) Federal Requirements District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard SE 39 Procedures used to provide services to eligible students enrolled in private schools at private expense 1. On or before December 1, the district determines the number of eligible private school students in consultation with private school representatives. Medford Public Schools Coordinated Program Review Final Report Page 72 of 152 CRITERION NUMBER Legal Standard 2. To the extent that the school district provides and pays for special education services for eligible students enrolled in private schools at private expense, the following requirements and procedures are implemented: a. The district provides special education and/or related services designed to meet the needs of eligible children who are attending private schools at private expense and whose parents reside in the jurisdiction of the school district. The school district provides to such children genuine opportunities to participate in the public school special education program consistent with state constitutional limitations. b. The district provides or arranges for the provision of evaluation services and an IEP for any eligible private school child whose parent resides in the jurisdiction of the school district. The evaluation may take place in the public school, the private school, or an appropriate contracted facility, and the school district ensures that a representative of the child’s private school is invited to participate as a member of the Team pursuant to §28.05. c. The district provides or arranges for the provision of the special education and/or related services described by the child’s IEP and the district ensures that special education services funded with state or local funds are provided in a public school facility or other public or neutral site. When services are provided using only federal funds, services are provided on public or private school grounds. d. The district does not withdraw or withhold services from a child solely because the school district has met the spending requirements of federal law. 3. Special education services and/or related services provided by the district to a private school child are comparable in quality, scope, and opportunity for participation to that provided to public school children with needs of equal importance. 4. The district ensures that programs in which both public and private school children participate do not include classes that are separated on the basis of school enrollment or the religious affiliation of the children. 5. An expedited special education evaluation, which is limited to a child’s physician statement unless there is a clear indication of the need or unless the parents request additional evaluation, is conducted and service provided to eligible students by the district within 15 calendar days of the school district’s receipt of the child’s physician statement. State Regulations 28.03(1)(e); Chapter 71B, section 2 Federal Requirements 34 CFR 300.450-300.462 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 73 of 152 CRITERION NUMBER Legal Standard SE 40 Instructional grouping requirements for students aged five and older 1. The size and composition of instructional groupings for eligible students receiving services outside the general education classroom are compatible with the methods and goals stated in each student's IEP. 2. Instructional grouping size requirements are maximum sizes and the school district exercises judgment in determining appropriate group size and supports for smaller instructional groups serving students with complex special needs. 3. When eligible students are assigned to instructional groupings outside of the general education classroom for 60% or less of the students’ school schedule, group size does not exceed eight (8) students with a certified special educator, twelve (12) students if the certified special educator is assisted by one aide, and sixteen (16) students if the certified special educator is assisted by two aides. 4. For eligible students served in settings that are substantially separate, serving solely students with disabilities for more than 60% of the students’ school schedule, the district provides instructional groupings that do not exceed eight (8) students to one certified special educator or twelve (12) students to a certified special educator and an aide. 5. After the school year has begun, if instructional groups have reached maximum size as delineated in paragraphs 3 and 4 of this criterion, the Administrator of Special Education and the certified special educator(s) providing services in an instructional group may decide to increase the size of an instructional grouping by no more than two additional students if the additional students have compatible instructional needs and then can receive services in their neighborhood school. 6. In such cases, the Administrator provides written notification to the Department and the parents of all group members of the decision to increase the instructional group size and the reasons for such decision. Such increased instructional group sizes are in effect only for the year in which they are initiated. 7. The district takes all steps necessary to reduce the instructional groups to the sizes outlined in paragraph 3 or 4 of this criterion for subsequent years. Such steps are documented by the district. State Regulations Federal Requirements 28.06(6) District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Documentation indicates that the district has exceeded the class size requirements for a number of classes at the high school. In addition, there is a lack of oversight and monitoring regarding adherence to the class size requirements. At the middle school when the student enrollment increases to over nine students, the designated classroom space for the resource room is not adequate to provide instruction to the increased number of students. Medford Public Schools Coordinated Program Review Final Report Page 74 of 152 CRITERION NUMBER Legal Standard SE 41 Age span requirements The ages of the youngest and oldest child in any instructional grouping do not differ by more than forty-eight months. A written request for approval of a wider age range is submitted to the Commissioner of Education in cases where the district believes it is justified. Such requests are implemented only after approval of the Department of Education. State Regulations 28.06(6)(f) Rating: Partially Implemented Federal Requirements District Response Required: Yes Department of Education Findings: Documentation indicates that the district has not adhered to the age span requirements for a number of classes at the high school level. In addition, there is a lack of oversight and monitoring regarding adherence to the age span requirements. CRITERION NUMBER Legal Standard SE 42 Programs for young children three and four years of age General requirements: 1. The school district ensures programs are available for eligible children three and four years of age. Such programs shall be developmentally appropriate and specially designed for children ages three and four years. 2. Where at all possible the school district accepts referrals from the Department of Public Health, other agencies, and individuals for young children when or before the child turns two-and-one-half years old in order to ensure continuity of services and to ensure the development and implementation of an IEP for eligible children by the date of the child's third birthday in accordance with federal requirements. 3. Where appropriate, the school district elects, consistent with federal requirements to use the format and services of the Individualized Family Service Plan (IFSP), if appropriate, for an additional year as a means of transitioning eligible children to public school services. 4. Where appropriate the Team allows a child to remain in a program designed for three and four year old children for the duration of the school year in which the child turns five years old (including the summer following the date of the child's fifth birthday). Types of Settings: Medford Public Schools Coordinated Program Review Final Report Page 75 of 152 CRITERION NUMBER Legal Standard 5. 6. Inclusionary programs for young children are located in a setting that includes children with and without disabilities and meet the following standards: a. Services in such programs are provided in the home, the public school, Head Start, or a licensed childcare setting. b. For public school programs that integrate children with and without disabilities, the class size does not exceed twenty (20) with one teacher and one aide and no more than five (5) students with disabilities. If the number of students with disabilities is six (6) or seven (7) then the class size does not exceed fifteen (15) students with one teacher and one aide. Substantially separate programs for young children are located in a public school classroom or facility that serves primarily or solely children with disabilities. Substantially separate programs adhere to the following standards: a. Substantially separate programs are programs in which more than 50% of the children have disabilities. b. Substantially separate programs operated by the district limit class sizes to nine (9) students with one teacher and one aide. State Regulations 28.06(7) Rating: Implemented CRITERION NUMBER Federal Requirements 34 CFR 300.342(c) District Response Required: No CIVIL RIGHTS METHODS OF ADMINISTRATION IV. CURRICULUM AND INSTRUCTION Legal Standard MOA 7A School Year Schedules 1. Before the beginning of each school year, the school district sets a school year schedule for each school. The school year includes at least 185 school days for students in grades 1-12 at each elementary, middle, and secondary school in the district, and these schools are in operation for at least 180 days a year for these students. 2. The school district ensures that unless his or her IEP or Section 504 Accommodation Plan provides otherwise, each elementary school student is scheduled for at least 900 hours of structured learning time a year and each secondary school student is scheduled for at least 990 hours of structured learning time a year, within the required school year schedule. Where the school district operates separate middle schools, it designates each one as either elementary or secondary. 3. Where the school district sets a separate school year and school day schedule for kindergarten programs, it provides at least 425 hours of structured learning time a year. If the district schedules two sessions of kindergarten a Medford Public Schools Coordinated Program Review Final Report Page 76 of 152 CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION IV. CURRICULUM AND INSTRUCTION Legal Standard day, it ensures equal instructional time for all kindergarten students. M.G.L. c. 69, s. 1G; 603 CMR 27.03, 27.04 District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard MOA 7B Structured Learning Time 1. The school district ensures that its structured learning time is time during which students are engaged in regularly scheduled instruction, learning, or assessments within the curriculum of core subjects and other subjects as defined in 603 CMR 27.02 (including physical education, required by M.G.L. c. 71, s. 3). The district’s structured learning time may include directed study (activities directly related to a program of studies, with a teacher available to assist students), independent study (a rigorous, individually designed program under the direction of a teacher, assigned a grade and credit), technology-assisted learning, presentations by persons other than teachers, school-to-work programs, and statewide student performance assessments. 2. The district ensures that its structured learning time does not include time at breakfast or lunch, passing between classes, in homeroom, at recess, in nondirected study periods (study halls), participating in optional school programs, or receiving school services such as health screening, speech, or physical and occupational therapy, except where those services are prescribed by a student’s IEP or Section 504 Accommodation Plan. 3. The hours spent in any type of structured learning time are verified by the school district. Where the school district counts independent study or a school-to-work program as structured learning time, it has guidelines that explain clearly how hours spent by students are verified. M.G.L. c. 69, s. 1G; 603 CMR 27.02, 27.04 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 77 of 152 CRITERION NUMBER Legal Standard MOA 7C Early Release of High School Seniors When the school district schedules the early release at the end of the year of the senior class of a high school, it does so in accordance with a written policy that conforms with Board of Education requirements under 603 CMR 27.05, ensuring that neither the conclusion of the seniors’ school year nor graduation is more than 12 school days before the regular scheduled closing date of that school. M.G.L. c. 69, s. 1G; 603 CMR 27.05 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 8 Accessibility of extracurricular activities Extracurricular activities sponsored by the district are nondiscriminatory in that: the school provides equal opportunity for all students to participate in intramural and interscholastic sports; extracurricular activities or clubs sponsored by the school do not exclude students on the basis of race, sex, color, religion, national origin, sexual orientation, disability, or homelessness. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a), (b); Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.41; Section 504: 29 U.S.C. 794; 34 CFR 104.4,104.37(a), (c); Title II: 42 U.S.C. 12132; 28 CFR 35.130; NCLB: Title X, Part C, Sec. 721; Mass. Const. amend. art 114; M.G.L. c. 76, s. 5; 603 CMR 26.06 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 9 Hiring and employment practices of prospective employers of students 1. The district requires employers recruiting at the school to sign a statement that the employer complies with applicable federal and state laws prohibiting discrimination in hiring or employment practices. 2. Prospective employers to whom this criterion applies include those participating in career days and work-study and apprenticeship training Medford Public Schools Coordinated Program Review Final Report Page 78 of 152 CRITERION NUMBER Legal Standard programs, as well as those offering cooperative work experience. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(b)(1),(2); Title IX: 20 U.S.C. 1681; 34 CFR 106.38; Section 504: 29 U.S.C. 794; 34 CFR 104.4(b)(1)(v), 104.37(a); Title II: 42 U.S.C. 12132; 28 CFR 35.130(b)(1)(v); M.G.L. c. 76, s. 5; 603 CMR 26.07(5) District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Refer to finding under CTE 12 TITLE 1 IV. CURRICULUM AND INSTRUCTION CRITERION NUMBER Legal Standard TI 24 - TAS The district implements effective instructional strategies that are based on scientifically-based research that: a. give primary consideration to extended learning time; b. help provide an accelerated, high quality curriculum; and c. minimize the removal of students from the classroom during regular hours. 1115(c)(1)(C) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 25 – TAS/SWP The school district provides opportunities for students receiving Title I services to participate in extended day/week/year programs and activities that the district offers. 1114(b)(1)(B)(ii)(II); 1115(c)(1)(C)(i) NCLB District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard TI 26 - SWP For each school a comprehensive Schoolwide Program (SWP) plan has been developed with the involvement of the community, those served by the program, and the individuals who will implement the plan, including: 1. a year of planning, Medford Public Schools Coordinated Program Review Final Report Page 79 of 152 CRITERION NUMBER Legal Standard 2. 3. 4. 5. 6. 7. teachers, principals, and other staff, and where appropriate, pupil services personnel, parents, secondary school students, if applicable, revision, as necessary, by the school, and availability of the plan to parents and the public in a language that parents can understand. 1114(b)(2)(B)(ii-iv) NCLB District Response Required: No Rating: Not Applicable Department of Education Findings: The district does not have any School-wide Programs in the Title I eligible schools. CRITERION NUMBER Legal Standard TI 27 - SWP The SWP plan includes a comprehensive needs assessment of the entire school that is based upon information on the performance of students in relation to the state academic content standards. 1114(b)(1)(A) NCLB District Response Required: No Rating: Not Applicable Department of Education Findings: The district does not have any School-wide Programs in the Title I eligible schools CRITERION NUMBER Legal Standard TI 28- SWP In providing technical assistance and support to schoolwide programs, the district ensures that the programs and plans contain all ten required schoolwide components, and are designed to ensure that each school will make Adequate Yearly Progress (AYP). 1112(c)(1)(C); 1114(b)(1) and (2) NCLB District Response Required: No Rating: Not Applicable Department of Education Findings: The district does not have any School-wide Programs in the Title I eligible schools. Medford Public Schools Coordinated Program Review Final Report Page 80 of 152 SAFE AND DRUG FREE SCHOOLS IV. CURRICULUM AND INSTRUCTION CRITERION NUMBER Legal Standard SDF 4 Local SDFSCA activities (where applicable) are integrated with the following federal programs under No Child Left Behind (NCLB): Title I (helping disadvantaged children meet high standards); Title II (professional development); Title IV B 21st Century Learning Center programs Title V (innovative education program strategies); [Title IV Sec. 4114 (d) (2) (A)] Rating: Implemented District Response Required: No CAREER AND TECHNICAL EDUCATION IV. CURRICULUM AND INSTRUCTION CRITERION NUMBER Legal Standard CTE 8 Programs are structured to improve academic and technical skills of all students. Perkins Section 135; Chapter 74 603 CMR 4.03 (4); 4.06 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Programs are structured to improve academic and technical skills of all students. Perkins Section 135; Chapter 74 603 CMR 4.03 (4); 4.06 Perkins and Chapter 74 Criteria: Based on interviews, the vast majority of staff, including administration and community partners, verbalized low expectations of Medford Vocational Technical High School (MVTHS) students, describing them as “unmotivated”, “narrow,” “low level”, “not college material”. Comparison and analysis of print materials from both high schools supports this. For example, MVTHS curriculum brochure describes its Dual Curriculum Program as distinguishing students planning to pursue post secondary education from those who are not. Based on record reviews and interviews, while a number of academic and technical courses and programs provide evidence of challenging coursework and high expectations, this was not true of all courses and programs. Several teachers do not assign homework, while others reported being satisfied if students attempted the work, citing students’ work demands and personal challenges as obstacles. Although the Program of Studies and students’ schedules provide an opportunity to take Advanced Placement and Honors level courses at Medford High School, career/vocational technical education students are not expected or encouraged to do so. Medford Public Schools Coordinated Program Review Final Report Page 81 of 152 CRITERION NUMBER Legal Standard CTE 9 Technology is used to improve academic and technical education. Perkins Section 135; Chapter 74 603 CMR 4.03 (4) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Technology is used to improve academic and technical education. Perkins Section 135; Chapter 74 603 CMR 4.03 (4) Perkins and Chapter 74 Criteria: Based on observations and interviews with staff and students, there is limited and inequitable access to technology (despite the 2001 Medford Vocational Technical High School Corrective Action Plan). In interviews with staff, it was reported that computer literacy is not required at MVTHS since it is “taught in the middle schools”; however, high school staff report a computer literacy course is a requirement of graduation at Medford High School. The computer opportunities that do exist (e.g., in the MHS library) are rarely promoted and utilized by career/vocational technical education students. While most programs have one or two computers, there is no evidence in student portfolios or competency checklists of computer based skill expectations. It was reported that computers once available in the Technology Enhanced Academics (TEA) classes were vandalized. To date, no efforts have been made to restore or remedy the problem. The new Marketing program, explored this year by ninth graders, depends upon the same technology resources as the TEA. Based on interviews with students and staff, few students chose to enroll in the Marketing program, in part due to insufficient technology. Although the district’s 2001 Corrective Action Plan referenced an online Advanced Placement course, there was no evidence that this course was an option accessed by MVTHS students. CRITERION NUMBER Legal Standard CTE 10 Linkages between secondary and postsecondary programs exist and are accessible to all students. Perkins Sections 13, 201; Chapter 74 603 CMR 4.03 (4) District Response Required: Rating: Partially Implemented Medford Public Schools Coordinated Program Review Final Report Yes Page 82 of 152 Department of Education Findings: Linkages between secondary and postsecondary programs exist and are accessible to all students. Perkins Sections 13, 201; Chapter 74 603 CMR 4.03 (4) Perkins and Chapter 74 Criteria: While articulation agreements with registered apprenticeship programs and opportunities to visit postsecondary institutions are in place for some programs, such as HVAC, postsecondary linkages are largely under-developed and under-utilized. Many staff describe Medford Vocational Technical High School students, with the support of their parents/guardians, as being more motivated to work. In contrast, interviews with parents/guardians revealed that all expected their sons/daughters to pursue postsecondary education. All students enrolled in programs that have articulation agreements are provided information on Tech-Prep, but in English only. While several students participate in Tech-Prep activities very few registration forms have the required parent/guardian signature. Additionally, there is little evidence of the required encouragement and support of Tech-Prep students transitioning to postsecondary education. CRITERION NUMBER Legal Standard CTE 11 All students are provided with strong experience in, and a comprehensive understanding of, all aspects of an industry (AAI). Perkins Section 135; Chapter 74 603 CMR 4.03 (4) (7) Definition: “All aspects…” means strong experience in, and comprehensive understanding of, the particular industry that a student is preparing to enter. Programs must provide students with understanding and experience in technical skills, business skills related to the particular industry (planning, management, financial, labor, legal, ethical, community), as well as health and safety, underlying principals of technology and environmental issues related to that industry. Rating: Partially Implemented District Response Required: Yes Department of Education Findings: All students are provided with strong experience in and understanding of all aspects of an industry. Perkins Section 135; Chapter 74 603 CMR 4.03 (4)(7) Perkins and Chapter 74 Criteria: Staff interviews and classroom observations indicate that curricula inconsistently include” All Aspects of Industry”. Medford Public Schools Coordinated Program Review Final Report Page 83 of 152 CRITERION NUMBER Legal Standard CTE 12 Cooperative Education activities are in compliance with 603 CMR 4.03 (7) Chapter 74 603 CMR 4.03 (7), Chapter 385 of the Acts of 2002 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Cooperative education Activities are in compliance with 603 CMR 4.03 (7), Chapter 385 of the Acts of 2002. 603 CMR 4.03 (7) Chapter 74 603 CMR 4.03 (7); Chapter 385 of the Acts of 2002 Chapter 74 and Section 385 Criteria Based on documentation review and interviews, while the Cooperative Education program is described as being "under close supervision of the coordinator", there is little, and in many cases, no management and supervision of approximately 20 students at work sites due to the fact that the coordinator is also a full time Vocational Technical Education (VTE) teacher. Based upon interviews at worksites with students and employers, students are not provided safety orientation from the employer when beginning the cooperative education position. There was no evidence of orientation or training on child labor laws provided by the school (or references to resource materials explaining the child labor laws), although employers agree to meet the provisions of these laws on the Worksite Agreement Form. Further, the Worksite Agreement Form contains language about the child labor laws that is overly general and technically incorrect. Based upon a review of files, some Worksite Agreement Forms were not signed by participating employers. The circumstances under which a CORI check may occur are not clear in the Cooperative Education policy. Based on interviews, the Cooperative Education Director and VTE teachers visit worksites on a sporadic basis due to time constraints. While efforts are made to track student progress by telephone, students reported few to no visits from their VTE teachers at the work site. Based on documentation and interviews, evaluation does not include assessment of technical competency attainment. Skills to be acquired by students are not listed on the written agreement. MVTHS has five students with disabilities participating in Cooperative Education. While the Cooperative Education Director informally notifies the employer of some of the accommodations a student may require at the work site, there is limited communication and no formal collaboration with the special education department. Medford Public Schools Coordinated Program Review Final Report Page 84 of 152 CRITERION NUMBER Legal Standard CTE 13 Required professional development is provided to staff. Perkins Section 135 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Required professional development is provided to staff. Perkins Section 135 Perkins and Chapter 74 Criteria: Based on interviews and documentation, while staff have access to district-wide and Perkins-funded professional development, it is not planned and provided based on data analyses or the academic and technical needs of CVTE students. Further, while most staff have recently completed professional development plans, there is little evidence that professional development is guided or monitored. CRITERION NUMBER Legal Standard CTE 14 Individuals who are members of special populations {that includes individuals with disabilities; individuals from economically disadvantaged families, including foster children; individuals preparing for nontraditional by gender training and employment; single parents, including single pregnant women; displaced homemakers; and individuals with other barriers to educational achievement including individuals with limited English proficiency} are provided with equal access to recruitment activities, admission and opportunities to a full range of courses of study without regard to race, color, gender, religion, national origin, English language proficiency, disability, or sexual orientation, and with programs that enable them to meet or exceed state adjusted levels of performance. Perkins Section 122, Chapter 76, section 5 [Chapter 622], Title IX; M.G.L. c.74 603 CMR 4.03 (4)(6)(7) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Individuals who are part of special populations (that include individuals with disabilities; individuals from economically disadvantaged families, including foster children; individuals preparing for nontraditional training and employment; single parents/guardians, including single pregnant women; displaced homemakers; and individuals with other barriers to educational achievement including individuals with limited English proficiency, are provided equal access to recruitment activities, admission and opportunities to a full range of courses of study without regard to race, color, gender, religion, national origin, English language proficiency, disability, or sexual orientation, and with programs that enable them to meet or Medford Public Schools Coordinated Program Review Final Report Page 85 of 152 exceed state adjusted levels of performance. Perkins Section 122, Chapter 76, section 5 (Chapter 622), Title IX; M.G.L. c.74 603 CMR 4.03 (4)(6)(7) Perkins Criteria: Documentation and interviews indicate that students with disabilities are not taught to the same challenging standards, as are all other students at Medford Vocational Technical High School. Several students with disabilities are not engaged in the full life of the school nor are they receiving the appropriate level and quality of instruction. For example, one class of students in The Learning Group (as described by the special education teacher, as an “incentive”), are rewarded for good behavior by going to the cafeteria for breakfast mid-morning, during academic class time, while the remaining 15 minutes of class time (described as being too short for a lesson) was used to allow students to develop skills in socializing with classmates. Technical teachers are not consistently provided information on students with IEP’s in a timely manner. In addition to students with limited English proficiency not being provided equal access to career/vocational technical information. MVTHS does not have a plan to ensure that students with limited English proficiency, and their parents/guardians, receive counseling and postsecondary information in a language they can understand. While there was nontraditional by gender enrollment in a majority of the career/vocational technical programs, review of Local Plan data and interviews demonstrated a clear need for professional development to support students enrolled in programs nontraditional for their gender. CRITERION NUMBER ENGLISH LEARNER EDUCATION IV. CURRICULUM AND INSTRUCTION Legal Standard ELE 8 Declining Entry to a Program The district provides English language support to students whose parents have declined entry to a sheltered English immersion, two-way bilingual, or other ELE program. (See Implementation Guidance below.) Authority: Title VI Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Documentation shows that the district has written procedures and translated documents in place when a parent declines entry of a Limited English Proficient student into a program required by Chapter 71A. . However, interviews and student record review indicate that these procedures are not in practice system-wide and the district has not designated personnel to be responsible for their implementation. Medford Public Schools Coordinated Program Review Final Report Page 86 of 152 CRITERION NUMBER Legal Standard ELE 9 Instructional Grouping 1. The district only groups students of different ages together in instructional settings if their levels of English proficiency are similar. 2. The district’s grouping of students ensures that LEP students receive effective content instruction at appropriate academic levels that is based on the Massachusetts curriculum frameworks. Authority: G.L. c. 71A, § 4; Title VI Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Documentation and interviews indicate that the district has based its curriculum on the Massachusetts Curriculum Frameworks and the English Language Proficiency Benchmarks and Outcomes. However, interviews also indicate that students of differing ages, are not always grouped according to similar levels of English language proficiency, but rather with mixed proficiency levels. CRITERION NUMBER Legal Standard ELE 10 Parental Notification 1. Upon placement in the ELE program, a notice is mailed to the parents or guardians written in the primary/home language, as well as in English, that informs parents of: (a) the reasons for identification of the student as Limited English Proficient (LEP); (b) the child’s level of English proficiency; (c) program placement and/or the method of instruction used in the program; (d) how the program will meet the educational strengths and needs of the student; (e) how the program will specifically help the child learn English; (f) the specific exit requirements; and (g) the parents’ right to apply for a waiver (see ELE 4), or to decline to enroll their child in the program (see ELE 9). (All districts need to comply with a-c and g. Title III districts must comply with a-g. Title III districts must send parental notification no later than 30 days after the beginning of the school year.) Medford Public Schools Coordinated Program Review Final Report Page 87 of 152 CRITERION NUMBER Legal Standard 2. The district will provide to parents and guardians of LEP students, report cards, and progress reports in the same manner and with the same frequency as general education reporting. The reports shall, to the maximum extent possible, be written in a language understandable to the parent/guardian. Authority: NCLB, Title III; c. 71A, §7; 603 CMR 14.02 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: The parental notification letter does not contain the above required elements: the ways in which the program will meet the student’s educational needs and strengths, and the specific exit criteria for the program in which the student is placed. Report cards and progress reports are not always documented in the student record and are not always translated in the primary language of the home, when necessary and appropriate. Medford Public Schools Coordinated Program Review Final Report Page 88 of 152 COMPONENT V: STUDENT SUPPORT SERVICES The criteria in this component examine whether the district has ensured that all students have equal opportunity and access to programs or services in the program areas listed below: Special Education (Report Issues # SE 43-49A) Civil Rights Methods of Administration (Report Issues MOA 10A –17A) Title I (Report Issues # TI 29A-29B) Career and Technical Education (Report Issues # CTE 15-16) English Learner Education (Report Issues # ELE 11-13) Medford Public Schools Coordinated Program Review Final Report Page 89 of 152 SPECIAL EDUCATION V. STUDENT SUPPORT SERVICES CRITERION NUMBER Legal Standard SE 43 Behavioral interventions For a student whose behavior impedes their learning or the learning of others, the Team considers the student’s behavior including positive behavioral interventions, ability to follow school discipline codes, any needed code modifications and the possible need for a functional behavioral assessment. State Regulations Rating: Partially Implemented Federal Requirements 300.346 District Response Required: Yes Department of Education Findings: IEP Teams consider the individual student’s need for behavioral intervention and incorporate the recommended goals and accommodations into the student’s IEP and behavior plan for students, who are placed in district-wide behavioral programs and at the alternative schools. However, for students placed in full and partial inclusion programs, IEP Teams do not always consider the student’s need for social-emotional and/or behavioral interventions and if recommended, do not always include goals and services into the student’s IEP to address the above needs. CRITERION NUMBER Legal Standard SE 44 Procedure for recording suspensions The district has a procedure to record the number and duration of suspensions, including any suspensions from any part of the student’s IEP program (including transportation). State Regulations Federal Requirements 34 CFR 300.121(d)(2) Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 90 of 152 CRITERION NUMBER Legal Standard SE 45 Procedures for suspension up to 10 days and after 10 days: General requirements 1. All students, including eligible students with disabilities, receive prior written notice regarding the school’s Code of Conduct. 2. The school’s Code of Conduct includes required procedural safeguards such as opportunity for a hearing (per Goss v. Lopez). 3. Any eligible student may be suspended up to 10 days in any school year without implementation of procedures described in criterion SE 46 below. 4. After a student with special needs has been suspended for 10 days in any school year, during any subsequent removal the public school provides sufficient services for the student to continue to receive a free and appropriate public education. 5. The school provides additional procedural safeguards for students with disabilities prior to any suspension beyond 10 consecutive days or more than 10 cumulative days (if there is a pattern of suspension) in any school year. State Requirements M.G.L. Ch. 76, Sections 16-18 and Ch. 71, Section 37 H Federal Requirements 34 CFR 300.519-300.529 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district 1. A suspension of longer than 10 consecutive days or a series of suspensions that are shorter than 10 consecutive days but constitute a pattern are considered to represent a change in placement. 2. Prior to a suspension that constitutes a change in placement of a student with disabilities, the Team convenes a. to develop or review a functional behavioral assessment of the student’s behavior to modify a behavior intervention plan or develop an assessment plan; b. to identify appropriate alternative educational setting(s); and c. to determine the relationship between the disability and the behavior - “a manifestation decision” (Is IEP appropriate? Is placement appropriate? If there was a behavior plan, was it implemented? Does student understand impact and consequences of his/her behavior? Can student control behavior?). Medford Public Schools Coordinated Program Review Final Report Page 91 of 152 CRITERION NUMBER Legal Standard 3. If the Team determines that the behavior is NOT a manifestation of the disability, then the district may suspend or expel the student consistent with policies applied to any student without disabilities, except that the district must still offer an appropriate education program to the student with disabilities that may be in some other setting. 4. Regardless of the manifestation determination, the district may place the student in an interim alternative educational setting (as determined by the Team) for up to 45 days a. if the behavior involves weapons or illegal drugs or another controlled substance while at school or a school function; or b. if the district provides evidence that the student is “substantially likely” to injure him/herself or others and a hearing officer orders the alternative placement; and c. the interim alternative education setting enables the student to continue in the general curriculum, to continue receiving services identified on the IEP, and provides services to address the problem behavior. 5. If the Team determines that the behavior IS a manifestation of the disability, then the district takes steps (with the consent of the parent) to correct the IEP, the placement, or the behavior intervention plan. 6. The school district provides written notice to the parent of all rights to appeal and to an expedited hearing. If the parent chooses to appeal, during the appeal the student stays put in the placement on the last accepted IEP or the interim alternative placement, unless the parent and the school district agree otherwise. State Regulations Rating: Implemented Federal Requirements 34 CFR 300.519-300.528 District Response Required: No CRITERION NUMBER Legal Standard SE 47 Procedural requirements applied to students not yet determined to be eligible for special education 1. If, prior to the disciplinary action, a district had knowledge that the student may be a student with a disability, then the district makes all protections available to the student until and unless the student is subsequently determined not to be eligible. The district may be considered to have prior knowledge if: a. The parent had expressed concern in writing; or b. The parent had requested an evaluation; or c. School district staff had expressed concern that the student had a disability. Medford Public Schools Coordinated Program Review Final Report Page 92 of 152 CRITERION NUMBER Legal Standard 2. If the district had no reason to consider the student disabled, and the parent requests an evaluation subsequent to the disciplinary action, the district must have procedures to conduct an expedited evaluation to determine eligibility. If the student is found eligible, then he/she receives all procedural protections subsequent to the finding of eligibility. 3. The school district has developed procedures consistent with federal requirements to expedite evaluations. State Regulations Rating: Implemented Federal Requirements 20 U.S.C. Chapter 33, Section 1415(k); 34 CFR 300.527 District Response Required: No CRITERION NUMBER Legal Standard SE 48 FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education All students receiving special education, regardless of placement, shall have an equal opportunity to participate in and, if appropriate, receive credit for the vocational, supportive, or remedial services that may be available as part of the general education program as well as the non-academic and extracurricular programs of the school. Programs, services and activities include, but are not limited to: 1. art and music 2. vocational education, industrial arts, and consumer and homemaking education 3. work study and employment opportunities 4. counseling services available at all levels in the district 5. health services 6. transportation 7. recess and physical education, including adapted physical education 8. athletics and recreational activities 9. school-sponsored groups or clubs 10. meals State Regulations 28.06(5) Rating: Partially Implemented Federal Requirements 34 CFR 300.121; 300.300-313 District Response Required: Yes Department of Education Findings: Refer to CTE 16 regarding the limited access for students with more significant disabilities to vocational technical programs, as well as work-study and employment opportunities. Medford Public Schools Coordinated Program Review Final Report Page 93 of 152 CRITERION NUMBER Legal Standard SE 49 Related services For each student with special education needs found to require related services, the school district provides or arranges for the provision of transportation and such developmental, corrective, and other supportive services as are required to assist a student to benefit from special education or to access the general curriculum, and includes: 1. speech-language pathology and audiology services 2. psychological services 3. physical therapy 4. occupational therapy 5. recreation, including therapeutic recreation 6. early identification and assessment of disabilities in children 7. counseling services, including rehabilitation counseling 8. orientation and mobility services (peripatology) 9. medical services for diagnostic or evaluation purposes 10. school health services 11. social work services in schools, and 12. parent counseling and training. State Regulations 28.02(19) Rating: Partially Implemented Federal Requirements 34 CFR 300.24 District Response Required: Yes Department of Education Findings: Student record review and interviews indicate that when counseling services are considered by the IEP Team and provided to the students, the service is not always documented in the student’s IEP. CRITERION NUMBER Legal Standard SE 49A Special Transportation If the IEP specifies that the student’s disability requires transportation or specialized transportation arrangements in order to benefit from special education, the district implements these provisions of the student’s IEP. 1. The Team determines necessary modifications, special equipment, assistance, need for qualified attendants on vehicles, and any particular precautions required by the student and documents such determinations in the student's IEP. If specialized arrangements can be provided on regular transportation vehicles, the school district makes such arrangements. Medford Public Schools Coordinated Program Review Final Report Page 94 of 152 CRITERION NUMBER Legal Standard 2. The district arranges to have eligible students who use wheelchairs transported in vehicles that do not require such children to be removed from their wheelchairs in order to enter or leave the vehicles; provided, however, that this requirement is not applicable where a Team or the student’s physician recommends that the student regularly transfer in and out of conventional vehicles to or from a wheelchair for therapeutic or for independence training reasons. 3. The Team specifies whether the student requires assistance in or out of the home, on or off of the vehicle, and in or out of the school. If such assistance is specified, the district ensures that it is provided. 4. The Team specifies if the student has a particular need or problem that may cause difficulties during transportation, such as seizures, a tendency for motion sickness, behavioral concerns, or communication disabilities. 5. The school district does not allow transportation considerations to influence, modify, or determine the educational program, including the length of the school day, required by any student. State Regulations 28.05(5)(b) Rating: Implemented CRITERION NUMBER Federal Requirements 34 CFR 300.24(b)(15) District Response Required: No CIVIL RIGHTS METHODS OF ADMINISTRATION V. STUDENT SUPPORT SERVICES Legal Standard MOA 10A Handbooks and codes of conduct 1. The district has a code of conduct for students and one for teachers. The principal of every school containing grades 9-12 prepares, in consultation with the school council, a student handbook containing the student code of conduct and distributes it to each student annually, as well as to parents and school personnel; the school council reviews and revises the student code of conduct every year. The principal of every school containing other grades distributes the district’s student code of conduct to students, parents, and personnel annually. At the request of a parent or student whose primary language is not English, a handbook or student code of conduct is translated into that language. 2. Student codes of conduct contain: a) procedures assuring due process in disciplinary proceedings and b) appropriate procedures for the discipline of students with special needs and students with Section 504 Accommodation Plans. 3. Handbooks and codes of conduct reference M.G.L. c. 76, s. 5 and contain: a) a nondiscrimination policy that is consistent with M.G.L. c. 76, s. 5, b) the school’s procedure for accepting, investigating and resolving complaints alleging discrimination or harassment; and c) the disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. Medford Public Schools Coordinated Program Review Final Report Page 95 of 152 and affirms the CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION V. STUDENT SUPPORT SERVICES Legal Standard Section 504; M.G.L. c. 71, s. 37H; 603 CMR 26.08 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: The district handbooks do not contain grievance procedures that clearly delineate the grievance process, including the required steps and timeframe to be implemented when a complaint is filed with key district personnel. In addition, the handbooks do not describe the consequences that would result from the different violations listed in the discipline code, including the suspension procedures and procedural safeguards assuring due process in disciplinary proceedings per Goss vs. Lopez and M.G.L., s. 37H. In addition, there was no evidence that district handbooks have been translated for parents whose primary language is not English or that there is a process in place for parents/guardians, whose primary language is not English, to request a translated copy of the handbook, including the student code of conduct. CRITERION NUMBER Legal Standard MOA 11A Designation of liaison/coordinator(s); grievance procedures The district has designated one or more staff persons to serve as liaison for homeless students, carrying out the duties described in NCLB: Title X, Part C, Sec. 722(g)(6), and to serve as coordinator for compliance with its responsibilities under Title IX, Section 504, and (if it employs 50 or more persons) Title II. The district has adopted and published grievance procedures for students and for employees providing for prompt and equitable resolution of complaints alleging discrimination based on sex or disability. Title IX: 20 U.S.C. 1681; 34 CFR 106.8; Section 504: 29 U.S.C. 794; 34 CFR 104.7; Title II: 42 U.S.C. 12132; 28 CFR 35.107; NCLB: Title X, Part C, Sec. 722(g)(1)(J)(ii) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to MOA 10A regarding grievances procedures. Medford Public Schools Coordinated Program Review Final Report Page 96 of 152 CRITERION NUMBER Legal Standard MOA 12A Annual and continuous notification concerning nondiscrimination and coordinators 1. If the district offers vocational education programs, it advises students, parents, employees and the general public before the beginning of each school year that all vocational opportunities will be offered regardless of race, color, national origin, sex or disability. The notice includes a brief summary of program offerings and admission criteria and the name(s), office address(es), and phone number(s) of the person(s) designated under MOA 11A to coordinate compliance under Title IX and Section 504. 2. In all cases, the district takes continuing steps to notify applicants, students, parents, and employees (including those with impaired vision or hearing), as well as unions or professional organizations holding collective bargaining or professional agreements with the district, that it does not discriminate on the basis of race, color, national origin, sex, or disability. This notice, also, includes the name(s), office address(es), and phone number(s) of the person(s) designated under MOA 11A to coordinate compliance under Title IX and Section 504. 3. Written materials and other media used to publicize a school include a notice that the school does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation. Title VI: 42 U.S.C. 2000d; 34 CFR 100.6(d); Title IX: 20 U.S.C. 1681; 34 CFR 106.8(a), 106.9; Section 504: 29 U.S.C. 794; 34 CFR 104.8; M.G.L. c. 76, s. 5; 603 CMR 26.02(2) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to finding under CTE 4 regarding the vocational school handbook. CRITERION NUMBER Legal Standard MOA 13 Availability of information and counseling on general curricular and occupational/vocational opportunities Students from linguistic, racial, and ethnic minorities; males; females; homeless students; and students with disabilities all receive, in grades 7-12, the same information and counseling as other students on the full range of general curricular and any occupational/vocational opportunities available to them. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a), (b); Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.36; Section 504: 29 U.S.C. 794; 34 CFR 104.4, 104.37(b); Title II: 42 U.S.C. 12132; 28 CFR 35.130; NCLB: Title III, Part A, Sec. 3121(c)(1)(C); Title X, Part C, Sec. 721; Mass. Const. amend. art. 114; M.G.L. c. 71A, s. 7; c. 76, s. 5; 603 Medford Public Schools Coordinated Program Review Final Report Page 97 of 152 CRITERION NUMBER Legal Standard CMR 26.03 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews and documentation indicate that the district has no system in place for limited English proficient students to receive information and counseling in a language that they can understand. Refer to finding under CTE 7and CTE 14. CRITERION NUMBER Legal Standard MOA 14 Counseling and counseling materials free from bias and stereotypes To ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, religion, national origin, sexual orientation, disability, and homelessness, all counselors: 1. encourage students to consider programs of study, courses, extracurricular activities, and occupational opportunities on the basis of individual interests, abilities, and skills; 2. examine testing materials for bias and counteract any found bias when administering tests and interpreting test results; 3. communicate effectively with limited-English-proficient and disabled students and facilitate their access to all programs and services offered by the district; 4. provide limited-English-proficient students with the opportunity to receive counseling in their primary language; 5. support students in educational and occupational pursuits that are nontraditional for their gender. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a), (b); EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.36; Section 504: 29 U.S.C. 794; 34 CFR 104.4, 104.37; Title II: 42 U.S.C. 12132; 28 CFR 35.130, 35.160; NCLB: Title III, Part A, Sec. 3121(c)(1)(C); Title X, Part C, Sec. 721; Mass. Const. amend. art. 114; M.G.L. c. 71A, s. 7; c. 76, s. 5; 603 CMR 26.04, 26.07(8) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to findings under CTE 14 and MOA 13 regarding the provision of guidance and counseling services to limited English proficient students in their primary language, when necessary and appropriate. Medford Public Schools Coordinated Program Review Final Report Page 98 of 152 CRITERION NUMBER Legal Standard MOA 14A Policies and practices to prevent stigmatization and segregation of homeless students The school district has adopted policies and practices to ensure that homeless students are not stigmatized or segregated on the basis of their being homeless. NCLB: Title X, Part C, Sec. 722(g)(1)(J) (i) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 14B Comparability of services for homeless students If they meet any eligibility criteria, homeless students are provided services comparable to services offered to other students in the school, including: Title I services; educational programs for students with disabilities; educational programs for students with limited English proficiency; programs in vocational and technical education; and programs for gifted and talented students. NCLB: Title X, Part C, Sec. 722 (g)(4) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 15 Non-discriminatory administration of scholarships, prizes and awards Scholarships, prizes and awards sponsored or administered by the district are free of restrictions based upon race, color, sex, religion, national origin, sexual orientation or disability. Schools may post or print information regarding private restricted scholarships as long as no preferential treatment is given to any particular scholarship offered and as long as the school does not endorse or recommend any such scholarship nor advise or suggest to a particular student that he or she apply for such a scholarship. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3; Title IX: 20 U.S.C. 1681; 34 CFR 106.31, 106.37; Section 504: 29 U.S.C. 794; 34 CFR 104.4(b)(1)(v); Title II: 42 U.S.C. Medford Public Schools Coordinated Program Review Final Report Page 99 of 152 CRITERION NUMBER Legal Standard 12132; 28 CFR 35.130(b)(1)(v); Mass. Const. amend. art. 114; M.G.L. c. 76, s. 5; 603 CMR 26.07(7) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews and the review of documentation showed no evidence that information regarding the availability of individual scholarships, prizes and awards is translated into languages other than English or that a protocol is in place for making this information available to limited English proficient students in a language that they could understand. CRITERION NUMBER Legal Standard MOA 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion 1. Within ten days from a student’s fifteenth consecutive unexcused absence, the school provides written notice to students age 16 or over and their parents or guardians. The notice is in English and the family’s native language and states that the student and the parent or guardian may meet with a representative of the district within ten days from the date the notice was sent. At the request of the parent or guardian, the district may consent to an extension of the time for the meeting of not longer than fourteen days. 2. At the meeting the participants discuss the reasons that the student is leaving school and alternative educational or other placements. The student and parent or guardian are told that attendance is voluntary after the student turns 16 but are also informed of the student’s right to return to school. M.G.L. c. 76, ss. 5, 18; St. 1965, c. 741 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 17A Use of physical restraint on any student enrolled in a publicly-funded education program 1. The district has developed and implemented staff training at least annually on the use of restraint consistent with regulatory requirements. Such training occurs within the first month of each school year and, for employees hired after the school year begins, within a month of their employment. Medford Public Schools Coordinated Program Review Final Report Page 100 of 152 CRITERION NUMBER Legal Standard 2. 3. 4. 5. The district administers physical restraint on students only when needed to protect a student and/or a member of the school community from imminent, serious, physical harm. The district implements restraint procedures consistent with Department of Education regulations in order to prevent or minimize any harm to the student as a result of the use of physical restraint. The district has developed written procedures regarding appropriate responses to student behavior that may require immediate intervention. Such procedures are annually reviewed and provided to school staff and made available to parents of enrolled students. The district has developed and implemented reporting requirements and procedures for administrators, parents and the Department of Education consistent with the regulations. The district has developed and implemented any applicable individual waiver procedures consistent with the regulations. M.G.L. c. 71, s. 37G; 603 CMR 46.00 Rating: Implemented CRITERION NUMBER District Response Required: No TITLE 1 V. STUDENT SUPPORT SERVICES Legal Standard TI 29A 1. Appropriate officials from private schools are informed and consulted about the availability of Title I services. Evidence of appropriate communication is maintained on file. 2. Written affirmation is obtained and signed by officials of each participating private school, confirming that required consultation has occurred. 1120 NCLB; 1421-1426 NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 29B 1. Appropriate officials from Neglected or Delinquent (N or D) facilities are informed and consulted about the availability of Title I services. A contract exists between the district and the N or D facility, if applicable. 2. The N or D program provides the appropriate academic and support services to enhance student achievement and provides a successful transition to noninstitutional settings for the participants. Medford Public Schools Coordinated Program Review Final Report Page 101 of 152 CRITERION NUMBER Legal Standard 1120 NCLB; 1421-1426 NCLB Rating: Not Applicable District Response Required: No Department of Education Findings: There are no neglected or delinquent facilities in the district. CRITERION NUMBER CAREER AND TECHNICAL EDUCATION Legal Standard CTE 15 Programs and services exist that support student participation in and completion of nontraditional by gender training and employment activities. Perkins Section 135; Chapter 74 603 CMR 4.03 (4) (7) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Programs and services exist that support student participation in and completion of nontraditional by gender training and employment activities. Perkins Section 135; Chapter 74 603CMR 4.03 (4)(7) Perkins Criteria: Documentation provided by the district included an anti-harassment/EEO policy, however there are no support services for students participating in programs nontraditional for their gender. CRITERION NUMBER Legal Standard CTE 16 The needs of students in alternative education programs are adequately addressed. Perkins Section 135 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: The needs of students in alternative education programs are adequately addressed. Perkins Section 135 Perkins Criteria: Based on interviews and a review of documentation, while there are several options within the district for students with more significant needs, not all students enrolled in these programs have full access Medford Public Schools Coordinated Program Review Final Report Page 102 of 152 to career/vocational technical programs and activities. For example, students in the Learning Group typically have access only to the exploratory program. Further, while students attending the Curtis Tufts Alternative High School can explore the Woodworking program, they currently do not have equal access to other Medford Vocational Technical High School vocational technical programs. CRITERION NUMBER ENGLISH LEARNER EDUCATION V. STUDENT SUPPORT SERVICES Legal Standard ELE 11 Equal Access to Academic Programs and Services 1. The districts does not segregate LEP students from their English-speaking peers, except when necessary, to implement an English learner education program. 2. The district ensures that LEP students participate fully with their Englishspeaking peers and are provided support in non-core regular public school courses. 3. The district ensures that LEP students have the opportunity to receive academic support services, such as guidance and counseling, in the student’s primary language. 4. The district ensures that LEP students are taught to the same academic standards and curriculum frameworks as all students, and provides the same opportunities to master such standards and frameworks as other students, including the opportunity to enter academically advanced classes, receive credit for work done, and have access to the full range of programs. 5. The district provides access to the full range of academic opportunities and supports afforded non-LEP students, such as those outlined in the District Curriculum Accommodation Plan (DCAP), access to special education services, and the implementation of Section 504 Student Accommodation Plans. 6. The district uses content objectives that are based on the Massachusetts curriculum frameworks in English language arts, history and social science, mathematics, and science and technology/engineering, taught by qualified staff members. Language objectives are also based on the Massachusetts English language arts standards, and those standards contained in the Massachusetts English Language Proficiency Benchmarks and Outcomes. Authority: Title VI; c. 71A, §7; 603 CMR 26.07 (8) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to findings under MOA 13, CTE 5, CTE 7, CTE 14 and ELE 5 regarding equal access for students with limited English proficiency to career/vocational technical information and for the parents/guardians and students to receive counseling and postsecondary information in a language they can understand at the vocational school. Further, LEP students are not always provided with sheltered English instruction in elective and nonacademic classes at the high school or at the vocational school. Medford Public Schools Coordinated Program Review Final Report Page 103 of 152 CRITERION NUMBER Legal Standard ELE 12 Equal Access to Nonacademic and Extracurricular Programs The district provides appropriate support, where necessary, to limited English proficient students to ensure that they have equal access to the nonacademic programs and extracurricular activities available to their English-speaking peers. Authority: Title VI; 603 CMR 26.06 (2) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: There is a lack of evidence regarding how information is made available to limited English proficient students at the middle and high school level, in a language that they can understand, to ensure equal access to the nonacademic programs and extracurricular activities. CRITERION NUMBER Legal Standard ELE 13 Follow-up Support 1. The district monitors students who have exited an English learner education program for two years and provides language support services to those students, if needed. 2. To the extent possible, the district provides access to adult basic education in English language and literacy skill instruction for LEP students who were previously enrolled in a public secondary school in the Commonwealth directly from a country other than the United States and who were unable to achieve English language proficiency as determined by assessments. Authority: Title VI; Chapter 218 of the Acts of 2002 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews and the student record review showed that there is no formal policy or procedures in place system-wide to track and monitor the provision of follow-up services to FLEP students. Interviews indicate that transition exit meetings are typically conducted when a limited English proficient student is exiting from an ELE program, but recommendations for follow-up support services and which personnel are responsible for the follow-up monitoring are not clearly documented. Medford Public Schools Coordinated Program Review Final Report Page 104 of 152 COMPONENT VI: FACULTY, STAFF AND ADMINISTRATION The criteria in this component examine whether the district has licensed staff, provides supervision of aides and tutors, and provides ongoing professional development in the program areas listed below. Additionally, the component examines whether the district implements an effective system of program leadership and oversight which fosters high standards and performance expectations for all students and staff consistent with the goals of applicable federal and state requirements and Education Reform Act of 1993. Finally, this component examines whether the district’s personnel procedures are nondiscriminatory and aimed at recruiting employees from all groups. : Special Education (Report Issues # SE 50-54) Civil Rights Methods of Administration (Report Issues MOA 18A-21) Title I (Report Issues # TI 30-31) Career and Technical Education (Report Issue # CTE 17) English Learner Education (Report Issues 14-15) Medford Public Schools Coordinated Program Review Final Report Page 105 of 152 CRITERION NUMBER SPECIAL EDUCATION VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard SE 50 Responsibilities of the School Principal and Administrator of Special Education Principal: 1. Instructional support. The principal in each of the district’s schools promotes instructional practices responsive to student needs and ensures that adequate instructional support is available for students and teachers. Instructional support includes remedial instruction for students, consultative services for teachers, availability of reading instruction at the elementary level, appropriate services for linguistic minority students, and other services consistent with effective educational practices and the requirements of M.G.L. c. 71B, §2. The principal consults with the Administrator of Special Education regarding accommodations and interventions for students. Such efforts and their results are documented and placed in the student record. Additionally, when an individual student is referred for an evaluation to determine eligibility for special education, the principal ensures that documentation on the use of instructional support services for the student is provided as part of the evaluation information reviewed by the Team when determining eligibility. 2. Curriculum Accommodation Plan. The principal implements a curriculum accommodation plan developed by the district’s general education program to ensure that all efforts have been made to meet the needs of diverse learners in the general education program. The plan assists the regular classroom teacher in analyzing and accommodating diverse learning styles of all children in the regular classroom and in providing appropriate services and support within the regular education program including, but not limited to, direct and systemic instruction in reading and provision of services to address the needs of children whose behavior may interfere with learning. The plan includes teacher training in (1) analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; (2) methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate such styles; and (3) training in the provision of pre-referral services within regular education, teacher mentoring and collaboration and parental involvement. (The plan may be part of a multi-year strategic plan.) 3. Coordination with special education. The principal with the assistance of the Administrator of Special Education coordinates the delivery and supervision of special education services within each school building. 4. Educational services in home or hospital. Upon receipt of a physician’s written order verifying that any student enrolled in a public school or placed by the public school in a private setting must remain at home or in a hospital on a day or overnight basis, or any combination of both, for medical reasons and for a period of not less than fourteen school days in any school year, the principal arranges for provision of educational services in the home or hospital. Such services are provided with sufficient frequency to allow the student to continue his or her educational program, as long as such services do not interfere with the medical needs of the student. The principal coordinates such services with the Administrator for Special Education for eligible students. Such educational Medford Public Schools Coordinated Program Review Final Report Page 106 of 152 CRITERION NUMBER SPECIAL EDUCATION VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard services are not be considered special education unless the student has been determined eligible for such services, and the services include services on the student’s IEP. Administrator of Special Education: 5. The school district has an appointed person to be its Administrator of Special Education. The Administrator supervises all special education for the school district and ensures compliance with all federal and state special education laws. As appropriate, and in accordance with the requirements of M.G.L. c.71B, §3A, the Administrator may designate other school district personnel to carry out some of the duties of the Administrator. State Regulations Federal Requirements 28.03(3) Chapter 71, Section 38Q and 38Q ½ Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews, student record review and documentation review indicate that the district has implemented a Teacher Assistance Team(TAT) process in each school building to provide instructional support interventions to address the diverse needs of the student population. The TAT teams at the elementary and the middle school have a consistent process and practices in place. However, at the elementary level, students who are limited English proficient and having difficulties with language related activities and class work in the general education classroom, are referred to the TAT Team process by classroom teachers who are not aware of the second language acquisition issues that present difficulties to a limited English proficient student and are not cognizant of the instructional strategies and accommodations needed to support the student At the secondary level, the high school’s practice is to conduct a TAT meeting, which typically results in a direct referral for a special education evaluation. The vocational school does not have a TAT process in place. CRITERION NUMBER Legal Standard SE 51 Appropriate special education teacher certification/licensure Individuals who design and/or provide direct special education services described in IEPs, or who supervise the provision of special education services by other teachers or paraprofessionals, are appropriately certified. State Regulations Federal Requirements 28.02(3) 34 CFR 300.23; 300.136 603 CMR 7.00 Rating: Implemented District Response Required: No Medford Public Schools Coordinated Program Review Final Report Page 107 of 152 CRITERION NUMBER Legal Standard SE 52 Appropriate certifications/licenses or other credentials -- related service providers Any person, including non-educational personnel, who provides related services described under federal special education law, who supervises paraprofessionals in the provision of related services, or who provides support services directly to the regular or special classroom teacher is appropriately certified, licensed, board-registered or otherwise approved to provide such services by the relevant professional standards board or agency for the profession. State Regulations 28.02(3) Federal Requirements 34 CFR 300.23; 300.24; 300.136 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard SE 53 Use of paraprofessionals 1. Paraprofessionals and assistants (e.g., teacher aides, tutors and student teachers) are appropriately trained to assist in providing special education or related services. 2. Persons employed as paraprofessionals and assistants do not design instruction for students with disabilities but are expected to implement instruction under the supervision of an appropriately certified or licensed professional who is proximate and readily available to provide such supervision. State Regulations Federal Requirements 34 CFR 300.136(f) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews indicate that paraprofessional staff are not always trained to assist in the delivery of services or instruction in the specific area(s) of the students’ educational and/or therapeutic need(s). At the high school and vocational school, the aides, often deliver the instruction with minimal or no supervision from a certified special education teacher. In addition, interviews indicate that paraprofessional staff, who are placed out in the workplace with students at job sites or assisting in the provision of ABA services in the home at the early childhood level, are not always sufficiently trained or provided with regular supervision. Medford Public Schools Coordinated Program Review Final Report Page 108 of 152 CRITERION NUMBER Legal Standard SE 54 Professional development regarding special education The district considers the needs of all staff in developing training opportunities for professional and paraprofessional staff and provides a variety of offerings which at a minimum include the following training topics offered on an annual basis: 1. state and federal special education requirements and related local special education policies and procedures; 2. confidentiality of student records; 3. training in analyzing and accommodating diverse learning styles of all students in order to achieve an objective of inclusion in the regular classroom of students with diverse learning styles; 4. methods of collaboration among teachers, paraprofessionals and teacher assistants to accommodate diverse learning needs of all students in the regular classroom; 5. training in the provision of pre-referral services within regular education, teacher mentoring and collaboration and parental involvement; 6. training for all locally hired and contracted transportation providers on the unique needs of all students being transported in regular and special transportation vehicles; and 7. in cooperation with the special education parent advisory council, at least one workshop annually within the district on the rights of students and their parents and guardians under the state and federal special education laws and makes written materials explaining such rights available upon request. State Regulations Chapter 71, Section 38g CMR 28.03(1)(a) and 28.06(8)(c) Chapter 71, Section 38Q and 38Q ½ Federal Requirements 34 CFR 300.382 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews indicate that there is a lack of professional development available for paraprofessional staff system-wide. Interviews indicate a need for teachers to gain greater understanding regarding the criteria for the identification of disabilities as well as, instructional strategies, accommodations and modifications to be implemented in the classroom for different types of disabilities, particularly students with behavioral and social-emotional issues. In addition, documentation and interviews indicate that there needs to be more widespread training in the following areas: assistive technology and applications for different disabilities; cross-collaboration across the curriculum by the special education, regular education and English Language Learner teaching staff in the areas of second language acquisition and understanding of different cultures. Medford Public Schools Coordinated Program Review Final Report Page 109 of 152 CIVIL RIGHTS METHODS OF ADMINISTRATION VI. FACULTY, STAFF AND ADMINISTRATION CRITERION NUMBER Legal Standard MOA 18A School district employment practices District employment practices in general are free from discrimination on the basis of race, color, national origin, sex, or disability. In particular, the district’s faculty salary scales are based on the conditions and responsibilities of employment without regard to race, color, national origin, sex, or disability, and the district’s employee recruitment is aimed at reaching all groups, including members of linguistic, ethnic, and racial minorities, females and males, and persons with disabilities. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(c); EEOA: 20 U.S.C. 1703(d); Title IX: 20 U.S.C. 1681; 34 CFR 106.51-106.61; Section 504: 29 U.S.C. 794; 34 CFR 104.11104.14; Title II: 42 U.S.C. 12132; 28 CFR 35.140; Mass. Const. amend. art 114 District Response Required: Yes Rating: Implemented Department of Education Findings: Documentation and interviews indicate that the district has done limited outreach to recruit teaching staff that reflect the changing population of the student community. CRITERION NUMBER Legal Standard MOA 19 Reserved CRITERION NUMBER Legal Standard MOA 20 Reserved CRITERION NUMBER Legal Standard MOA 21 Staff training regarding civil rights responsibilities The district provides in-service training for all school personnel at least annually regarding civil rights responsibilities, including the prevention of discrimination and harassment on the basis of students’ race, color, sex, religion, national origin and sexual orientation and the appropriate methods for responding to it in the school setting. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3; EEOA: 20 U.S.C. 1703(f); Title IX: 20 Medford Public Schools Coordinated Program Review Final Report Page 110 of 152 CRITERION NUMBER Legal Standard U.S.C. 1681; 34 CFR 106.31-106.42; M.G.L. c. 76, s. 5; 603 CMR 26.00, esp. 26.07(2), (3) Rating: Implemented CRITERION NUMBER District Response Required: No TITLE 1 VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard TI 30 1. All professional staff providing Title I services are appropriately licensed (or hold current licensure waivers) and are highly qualified for their job title and function. 2. Where applicable, the district’s Title IIA grant application describes how it will use these funds to meet the requirements of section 1119. 3. Each principal of a school that has a Title I program (whether a Schoolwide or a Targeted Assistance program) has attested in writing that the teachers within the school (Title I and non-Title I) who teach the core academic subjects have met or are working toward meeting the highly qualified teacher requirements. MGL Chapter 71, 38G 1119(a), (c), (d), and (f) NCLB 2122(b) 10 NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 31 Professional Development 1. The school district uses at least 5% of its Title I funds for professional development activities to ensure that teachers who are not highly qualified, become highly qualified. 2. Title I teachers are involved in the Title IIA professional development needs assessment. 1119(k)(1) NCLB 2122(c)(1)(2) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 111 of 152 CRITERION NUMBER CAREER AND TECHNICAL EDUCATION VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard CTE 17 All staff in Perkins-eligible programs (including Chapter 74-approved programs) are appropriately licensed as required by Chapter 74 Section 18 603 CMR 4.03 (5); 4.07 and Chapter 71 Section 38G 603 CMR 7.00? Perkins Section 135; Chapter 74 Section 18 603 CMR 4.03(5); 4.07, M.G.L. c.71Section 38G, M.G.L. c. 71, Section 59B, No Child Left Behind Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Based on the information submitted by the district, not all staff are listed in the Vocational Technical Education Staff Register (VTESR). Further, staff in the Non-Chapter 74 approved Construction Technology program are currently teaching without Massachusetts educator licensure. CRITERION NUMBER ENGLISH LEARNER EDUCATION VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard ELE 14 Licensure and Fluency Requirements 1. The district assures that all teachers in English language classrooms are literate and fluent in English. A teacher is literate in English if the teacher: (a) possesses a teaching license issued pursuant to G.L. c.71, section 38G; or (b) possesses a vocational teacher approval or a vocational technical educator license; or (c) earns a passing score on the Communication and Literacy Skills portion of the Massachusetts Tests for Educator Licensure (MTEL); or (d) possesses a Bachelor’s degree from a college or university where the language of instruction was English. English fluency may be determined through one or more of the following methods: (a) classroom observation and assessment by the teacher’s supervisor, principal, and/or superintendent or charter school leader; or (b) an interview and assessment by the teacher’s supervisor, principal, and/or superintendent or charter school leader; or (c) the teacher’s demonstration of fluency in English, through a test accepted by the Commissioner of Education; or (d) another method determined by the superintendent or charter school leader, and accepted by the Commissioner of Education. 2. Teachers and educational staff who are qualified and who teach in ELE programs hold the appropriate licenses or current waivers issued by the Medford Public Schools Coordinated Program Review Final Report Page 112 of 152 CRITERION NUMBER ENGLISH LEARNER EDUCATION VI. FACULTY, STAFF AND ADMINISTRATION Legal Standard Department of Education. 3. If the district has 200 or more LEP students and has a director of programs for LEP students who is employed in that position for one-half time or more, that director is certified in English as a Second Language, or Bilingual Education, or English Language Learners program license, and an administrator/supervisor license. 4. Although districts are required no later than July 2008 to have at least one teacher who is certified in ESL, or TBE, or ELL under Chapter 71A, under federal Title VI, districts are required to have certified and qualified staff. Authority: G.L. c. 71, § 38G; G.L. c. 71A, § 2; Chapter 218 of the Acts of 2002, §§ 24 and 25; Title VI; 603 CMR 14.05 Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard ELE 15 Professional Development Requirements District schools with LEP students implement a professional development plan that provides high quality training in second language acquisition and in working with culturally and linguistically diverse student populations. The school provides opportunities that ensure the progress of LEP students in developing oral comprehension, speaking, reading, and writing of English, and also in meeting academic standards and curriculum frameworks. Authority: M.G.L. c71, § 59C; NCLB, Title III Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews and the student record review indicate the need to provide professional development to the district staff across the curriculum in second language acquisition and the types of instructional strategies, modifications and accommodations to use when working with the culturally and linguistically diverse student population in each school building (Refer to SE 54). Medford Public Schools Coordinated Program Review Final Report Page 113 of 152 COMPONENT VII: SCHOOL FACILITIES The criteria in this component examine whether the district maintains facilities that are conducive to learning, facilitate integration, and provide equal access and opportunity for students to achieve in the program areas listed below: Special Education (Report Issues # SE 55) Civil Rights Methods of Administration (Report Issues MOA 22-23) Career and Technical Education (Report Issue # CTE 18) English Learner Education (Report Issue # ELE 16) Medford Public Schools Coordinated Program Review Final Report Page 114 of 152 SPECIAL EDUCATION VII. SCHOOL FACILITIES CRITERION NUMBER Legal Standard SE 55 Special education facilities and classrooms 1. The school district provides facilities and classrooms for eligible students which maximize the inclusion of such students into the life of the school; 2. Provide accessibility in order to implement fully each child’s IEP; 3. Are at least equal in all physical respects to the average standards of general education facilities and classrooms; and 4. Are given the same priority as general education programs for access to and use of instructional and other space in public schools in order to minimize the separation or stigmatization of eligible students. State Regulations 28.03(1)(b) Federal Requirements Section 504 of the Rehabilitation Act of 1973 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews, documentation and facility checks indicate that the space in the special education resource rooms at the middle and high school are adequate size for no more than 8-9 students. However, the student enrollment typically increases and can reach up to 12-15 students. The resource rooms at the middle school are windowless and have limited technological access(LCD) and limited storage space. At the high school, Rooms 117 and 122 are divided in half, poorly ventilated and used as special education spaces. At the McGlynn Elementary School, the life skills program for grades 2-5 is placed near the K-1 classrooms, and the middle school life skills program is placed in the elementary school, rather than in the middle school. CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION VII. SCHOOL FACILITIES Legal Standard MOA 22 Accessibility of district programs and services for students with disabilities In at least one facility within the district, the district makes available and entirely accessible to students with disabilities all educational and vocational programs and services offered at each level (preschool, elementary and secondary). Section 504: 29 U.S.C. 794; 34 CFR 104.21,104.22; Title II: 42 U.S.C. 12132; 28 CFR 35.149, 35.150; Mass. Const. amend. art. 114 Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 115 of 152 CRITERION NUMBER Legal Standard MOA 23 Comparability of facilities Where the district provides separate facilities for members of a specific group, those facilities are comparable to those offered other students in the district, including: 1. separate facilities for disabled, limited-English-proficient or pregnant students that are comparable to the facilities for other students in the district; 2. separate toilet, locker room, and shower facilities for students of one gender that are comparable in size, condition, number and location to those provided students of the other gender. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(b)(2); Title IX: 20 U.S.C. 1681; 34 CFR 106.33, 106.40(b)(3); Section 504: 29 U.S.C. 794; 34 CFR 104.34(c); Mass. Const. amend. art. 114; 603 CMR 28.03(1)(b) Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Refer to CTE 18, SE 55 and ELE 16 regarding comparability of facilities. CRITERION NUMBER CAREER AND TECHNICAL EDUCATION VII. SCHOOL FACILITIES Legal Standard CTE 18 Instructional facilities, equipment and supplies meet the current occupational standards as well as standards for a healthy, safe environment. Perkins Section 135; Chapter 74 603 CMR 4.03 (3) (4) (7)(8) Rating: Not Implemented District Response Required: Yes Department of Education Findings: During the review, a safety expert contracted by the Department carried out a safety inspection of Medford Vocational High School’s shops and related facilities. The safety expert identified 68 serious safety hazards that will require immediate corrective action. Serious hazards are defined as those that can cause an accident or health hazard exposure resulting in death or serious harm. Of the 68, the expert identified items 1, 2, 3, 14, 21, 27, 29, 30, 31 and 32 to be approaching imminent danger to students and staff. On Safety training is not provided to all staff and there is no school-wide Safety Plan. None of the 12 shops inspected were in full compliance with applicable Occupational Safety and Health Administration (OSHA) regulations. Jeffrey Wheeler, State Director of Career/Vocational Technical Education sent the report prepared by the safety expert to Superintendent Belson and Principal Mahoney on July 5, 2005. The district must begin rectifying the hazards immediately. All safety hazards must be corrected prior to the opening of the 2005-2006 school year Medford Public Schools Coordinated Program Review Final Report Page 116 of 152 There were several health violations, particularly in Culinary Arts, which was operating with an expired Food Establishment Permit. Further, the kitchen facilities were filthy, including staff and servers in dirty uniforms and many students did not have gloves on while preparing food. One student was witnessed eating off a serving utensil while preparing a meal and putting that same utensil back into the pot. Based on observation, despite the fact that the Medford Early Education Program (MEEP) has at least two children in wheelchairs, the handicap ramp accessibility at the main entrance was inadequate. Not all programs have up-to-date equipment to enable students to meet the requirements of the Certificate of Occupational Proficiency standards. Although the Machine Technology related instruction room is equipped with several computers, they are not updated and rarely used to assist in related instruction. On one occasion students were observed smoking at the MVTHS main entrance in the presence of a supervising staff member. The girls’ restroom and adjoining hallway had a heavy odor of smoke despite the presence of two staff on hall duty. During lunch periods, students eat, drink, and socialize in the halls and on stairways, obstructing passage, compromising sanitation and presenting potential safety hazards. Students at MVTHS have less access to the Health and Fitness course offered to the students at MHS through MHS. CRITERION NUMBER ENGLISH LEARNER EDUCATION VII. SCHOOL FACILITIES Legal Standard ELE 16 The district ensures that LEP students are provided facilities, materials and services comparable to those provided to the overall student population. Authority: Title VI; 603 CMR 26.07 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Interviews indicate that there is a shortage of materials and books available for students and teachers in English language support programs. One of the spaces designated for the ELL program at the Andrews Middle School is small. In addition, students are assigned to one classroom space for the entire day. There is an initiative to review the schedule at the middle school level to afford more time for the integration of the LEP students into the exploratory classes with their regular education peers. Medford Public Schools Coordinated Program Review Final Report Page 117 of 152 COMPONENT VIII: PROGRAM PLAN AND EVALUATION The criteria in this component examine whether the district has written program plans that are evaluated according to specific regulatory requirements and whether parents have opportunities for input on needs, program implementation, evaluation, and improvement in the program areas listed below: Special Education (Report Issue # SE 56) Civil Rights Methods of Administration (Report Issues MOA 23A-25) Title I (Report Issues # TI 32-38) Safe and Drug Free Schools (Report Issue # SDF 5-8) Career and Technical Education (Report Issue # CTE 19) English Learner Education (Report Issue #17) Medford Public Schools Coordinated Program Review Final Report Page 118 of 152 CRITERION NUMBER SPECIAL EDUCATION VIII. PROGRAM PLAN AND EVALUATION Legal Standard SE 56 Special education programs and services are evaluated 1. Special education programs, services and administrative areas are regularly evaluated. 2. The district develops methods for determining the effectiveness of programs in assisting students with disabilities to achieve the goals set forth in their IEPs in the least restrictive environment. 3. The district uses information it gathers from annual IEP reviews to measure the effectiveness of special education programs, and identifies programs, services and administrative areas that need improvement or must be developed. 4. As part of these evaluation procedures, the district measures the success of programs based on students’ local and statewide assessment results, drop out rates and graduation rates for special education students. State Regulations Chapter 71B, Section 2 Chapter 71, Section 59C Rating: Partially Implemented Federal Requirements 34 CFR 300.137 District Response Required: Yes Department of Education Findings: Documentation and interviews indicate that there is no formal regular evaluation of the special education programs and services on a continuous basis. The review of documentation showed an evaluation of the Learning Group Program in 2004. Interviews indicate that there are meetings, informal discussions and changes made to programs and services, but not on the basis of results emerging from a formal evaluation and/or self-assessment process. CRITERION NUMBER CIVIL RIGHTS METHODS OF ADMINISTRATION VIII. PROGRAM PLAN AND EVALUATION Legal Standard MOA 23A Review and revision of policies to remove barriers to the enrollment and retention of homeless children and youth The school district has adopted policies to remove barriers to the enrollment and retention of homeless children and youth in district schools; it regularly reviews and revises those policies. NCLB: Title X, Part C, Sec. 722(g)(1)(I), 722(g)(7) Rating: Implemented District Response Required: Medford Public Schools Coordinated Program Review Final Report No Page 119 of 152 CRITERION NUMBER Legal Standard MOA 24 Curriculum review The district ensures that teachers in the district review all educational materials for simplistic and demeaning generalizations, lacking intellectual merit, on the basis of race, color, sex, religion, national origin and sexual orientation. Appropriate activities, discussions and/or supplementary materials are used to provide balance and context for any such stereotypes depicted in such materials. M.G.L. c. 76, s. 5; 603 CMR 26.05(2) Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard MOA 25 Institutional self-evaluation The district evaluates all aspects of its K-12 program annually to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities. It makes such changes as are indicated by the evaluation. Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(b)(2); EEOA: 20 U.S.C. 1703(f); Section 504: 29 U.S.C. 794; 34 CFR 104.4(b)(4); Title II: 42 U.S.C. 12132; 28 CFR 35.130(b)(3); NCLB: Title III, Part A, Sec. 3121(c)(1)(C); Title X, Part C, Sec. 722(g)(1)(J)(i), 722(g)(7); Mass. Const. amend. art. 114; M.G.L. c. 71A, s. 7; c. 76, s. 5; 603 CMR 26.07(1),(4) Rating: Implemented District Response Required: Yes Department of Education Findings: The district, through the work of the Medford Human Rights Commission and Racially Balanced Advisory Committee, regularly track multicultural and multiracial efforts as evidenced in the K-12 curriculum. However, the documentation and data review, the student record reviews and interviews indicate that there are inconsistencies and inequities in the implementation of the equal access requirements that need to be addressed as referenced in MOA 3, MOA 4, ELE 5 and CTE 14. In addition, the Medford Human Rights Commission and Racially Balanced Advisory Committee committees need to develop a formal mechanism to evaluate all aspects of the K-12 program as delineated in the above criterion. Medford Public Schools Coordinated Program Review Final Report Page 120 of 152 CRITERION NUMBER Legal Standard MOA 26 Records for homeless students The school maintains for each homeless student records ordinarily kept by it, including immunization or medical records, academic records, birth certificates, guardianship records, and evaluations for special services or programs, so that the records are available, in a timely fashion, when the student enters a new school or school district. NCLB: Title X, Part C, Sec. 722(g)(3)(D) Rating: Implemented District Response Required: CRITERION NUMBER No TITLE 1 VIII. PROGRAM PLAN AND EVALUATION Legal Standard TI 32 A needs assessment and a data analysis are conducted annually in each Title I school (Targeted Assistance and Schoolwide programs) to determine the types of programs and services to be provided to Title I students, parents, and staff. The implemented program is evaluated for effectiveness annually and the resulting program changes are described. Meeting notes, summary of analysis of needs assessment data, written evaluation findings, and all relevant documents are available. 1114(b)(1)(A); 1115 (c)(2)(B) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 33 The adequate yearly progress (AYP) of each Title I school is evaluated in the aggregate and by subgroup, as available, on an annual basis. Title I program changes are implemented that reflect the results of this evaluation. 1114 (b)(2)(B)(iii); 1115 (c)(2)(B); 1116(A)(1)(A) and (B) NCLB Rating: Implemented District Response Required: Medford Public Schools Coordinated Program Review Final Report No Page 121 of 152 CRITERION NUMBER Legal Standard TI 34 Each Title I school identified as “in need of improvement” revises (not later than 3 months after being identified) a two-year school improvement plan in consultation with parents, staff, other district personnel, and outside experts that meets NCLB requirements. 1116(b)(3)(A) NCLB Rating: Implemented District Response Required: No Department of Education Findings: The Title I Schools are not identified as “in need of improvement”. CRITERION NUMBER Legal Standard TI 35 For schools that have been identified as “in need of improvement,” school improvement plans must be implemented not later than the beginning of next full school year following this identification. 1116(b)(3)(D) Rating: Implemented District Response Required: No Department of Education Findings: The Title I Schools are not identified as “in need of improvement”. CRITERION NUMBER Legal Standard TI 36 For any of the district’s Title I schools that have been identified as “in need of improvement,” the school spends at least 10% of its allocation of Title I funds to provide teachers and the school principal with high-quality professional development that directly addresses the problems associated with academic achievement in the school. 1116(b)(3)(A)(iii)(I) NCLB Rating: Implemented District Response Required: No Department of Education Findings: The Title I Schools are not identified as “in need of improvement”. Medford Public Schools Coordinated Program Review Final Report Page 122 of 152 CRITERION NUMBER Legal Standard TI 37 For schools that have been identified as “in need of improvement,” the district provides students enrolled in those schools the choice to transfer to another of the district’s schools not identified as in need of improvement and informs parents of this opportunity. Priority is given to the lowest achieving students from low-income families. 1116(b)(1)(E)(i) and (ii) NCLB 2763A-32 of P.L. 106-554 (Education Appropriations Act, 2001) Rating: Implemented District Response Required: No Department of Education Findings: The Title I Schools are not identified as “in need of improvement”. CRITERION NUMBER Legal Standard TI 38 For schools that continue to fail to make AYP after being identified as “in need of improvement,” the district: 1. Continues to make the choice to transfer option available to students; 2. Makes supplemental educational services available; For supplemental services, the district/school notifies parents of eligible students at least annually about the availability of supplemental educational services, objectively determines which students should receive services if all students can not be served, arranges for service to be provided, ensures that students with disabilities and students with limited English proficiency are served appropriately and when requested, assists the Department with monitoring the services provided; 3. The district addresses requirements for schools in Corrective Action (if applicable), and; 4. The district provides technical assistance to schools in improvement and/or corrective action status. 1116(b)(5) and 1116 (e) NCLB; 200.46 (4) and (5) Rating: Implemented District Response Required: No Department of Education Findings: The Title I Schools are not identified as “in need of improvement”. Medford Public Schools Coordinated Program Review Final Report Page 123 of 152 CRITERION NUMBER SAFE AND DRUG FREE SCHOOLS VIII. PROGRAM PLAN AND EVALUATION Legal Standard SDF 5 Each recipient bases its programs on a thorough assessment of objective data about the drug and violence problems in the schools and communities served. Each SDFSCA grant recipient conducts a through assessment of the nature and extent of youth drug use and violence problems. [Title IV Secs. 4111 – 4116] Rating: Commendable District Response Required: No Department of Education Findings: Based on documentation and interviews, Medford Public Schools has an exemplary process in place to determine the current level of substance abuse and violence among the student population in the community. In addition to administering the Youth Risk Behavior Survey, this year the district administered Communities that Care survey to give a clearer indication of the extent of youth drug use and alcohol. In addition the process included parent surveys and focus groups, teacher surveys, community focus groups, and meetings with parents, community leaders, teachers, advisory councils, students and task force members. Furthermore, Safe and Drug Free School reporting forms, Medford’s Police Crime Reports, disciplinary records at all levels and nurse’s logs are reviewed and analyzed. Interviews, meetings and data collection are also conducted regarding incidents/usage by youth from local law enforcement agencies, hospitals, health agencies and community agencies. There is documentation to support the statistics and incident information reported in the objective analysis of the district’s 2005 SDFSCA grant application. There is evidence that the objective analysis was based upon ongoing local assessment of activities and programs. CRITERION NUMBER Legal Standard SDF 6 Each recipient establishes a set of performance measures and designs its programs to meet those measures. [Title IV Sections 4114, (d) (B) (i) (I) (II) (ii) (C)] Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 124 of 152 CRITERION NUMBER Legal Standard SDF 7 Each recipient designs and implements its programs for youth based on research or evaluation that provides evidence that programs used are based on scientifically based research that provides evidence that the program to be used will reduce violence and illegal drug use. [NCLB, Title IV Section 4115, (a) (C)] Rating: Commendable District Response Required: No Department of Education Findings: Based on documentation, interviews and classroom observation, selected programs and activities respond to identified needs. These programs and activities are crafted on scientifically based research and evaluation that demonstrate evidence of program effectiveness in reducing and preventing drug use, violence and disruptive behavior among youth. Components being implemented include: Second Step, Bullying Program, Peer Mediation, Smoking Cessation, Gay Straight Alliance, SADD, Teen Health Teaching Modules, 2nd Hand Smoke Program Project Safeguard, STARS and Talking About Touching. All students participate in all activities and programs are adjusted when needed for students with special needs. The district has very clear expectations against violence and illegal use of drugs with appropriate, clear, consistent and wellenforced consequences in place for violation of policies. CRITERION NUMBER Legal Standard SDF 8 Each recipient shall conduct a periodic evaluation to assess its progress toward reducing violence and illegal drug use in schools to be served based on performance measures. [NCLB, Title IV Secs. 4115 (2) (A),(B)] Rating: Implemented CRITERION NUMBER District Response Required: No CAREER AND TECHNICAL EDUCATION VIII. PROGRAM PLAN AND EVALUATION Legal Standard CTE 19 The school has developed and implemented a system of program evaluation that includes, at a minimum, the following four core indicators and program outcomes. Perkins Section 113; Chapter 74 603 CMR 4.05) Perkins Act Core Indicators: Medford Public Schools Coordinated Program Review Final Report Page 125 of 152 CRITERION NUMBER CAREER AND TECHNICAL EDUCATION VIII. PROGRAM PLAN AND EVALUATION Legal Standard (1) Student attainment of challenging State established academic and technical skill proficiencies; (2) Student attainment of a secondary school diploma or its recognized equivalent, a proficiency credential in conjunction with a secondary school diploma, or a post secondary degree or credential; (3) Placement in, retention in, and completion of postsecondary education or advanced training, placement in military service, or placement or retention in employment; and (4) Student participation in and completion of career and technical education programs that lead to nontraditional training and employment. Chapter 74 Outcomes: 1. Outcome I - Effective with the Class of 2003, the percentage of vocational technical education students who receive a high school diploma. 2. Outcome II - Upon the development of the Certificate of Occupational Proficiency Assessment System, the percentage of vocational technical education students who receive a Certificate of Occupational Proficiency. Outcome III - The percentage of vocational technical education program graduates who are in a military program related to their program of study, employed related to their program of study or who are enrolled in postsecondary education or advanced training twelve months after graduation. District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Student records were incomplete. While placement data is used to evaluate program success, there is no additional system of evaluation or evidence that Perkins Core Indicators or Chapter 74 Outcomes are used for evaluation, modification and improvement of programs. The data and financial review that was conducted by K.P. Marshall Associates PC CPAs found several problematic areas. Please refer to the draft financial and data review report that was sent to Superintendent Belson by Jeffrey Wheeler, State Director of Career/Vocational Technical Education on July 12, 2005 Most Recent Perkins/Chapter 74 Data: Perkins: Medford did not meet state goals in the following areas: Core Indicator I - Academic Achievement (MCAS results) – 0 % of (0 /1) students with limited English proficiency passed the MCAS. Core Indicator II - Attainment of a Secondary Diploma – 85% of all students and 80% of economically disadvantaged students at the vocational school received a high school diploma(the goal for all student populations is 91.23%). Core Indicator III – Perkins Positive Placement – Overall, the state placement goal of 95.58% was met for all CTE students (97.46%) and overall, the positive placement for students with disabilities (based on a two-year average) is 100%. However, the following CTE programs did not meet the state Perkins placement goal of 95.58%: Electrician (92.31%), Automotive Body Repairer (93.75%) and Graphic & Printing Equipment Operator (90.00%). Medford Public Schools Coordinated Program Review Final Report Page 126 of 152 Core Indicator IV A - Nontraditional by Gender Enrollment – Medford reported an average of 7.91% nontraditional enrollment rate (8.87% for Tech Prep students). The state goal of 9.43% was not met. Core Indicator IV B – Nontraditional by Gender Completion – Medford reported a 6.0 % completion rate for students enrolled in programs non-traditional for their gender (7.41% for Tech Prep students), while the state goal is 8.10%. Chapter 74: The school district’s overall placement rate for the class of 2003 was 85.59% exceeding the Chapter 74 performance goal (70%.) However, the following career/vocational technical education programs did not meet the 70% standard: Child Care (66.67, or 2/3 students), Graphic & Printing Equipment Operator (60.00%, or 6/9 students) and Cabinetmaker & Mill worker (57.14%) and Childcare and Guidance Worker (33.33%, or 1/3 students). CRITERION NUMBER ENGLISH LEARNER EDUCATION VIII. PROGRAM PLAN AND EVALUATION Legal Standard ELE 17 DOE Data Submission Requirements and Program Evaluation 1. The district reports annually to the Department, the following student information: i.the schools in which LEP students are enrolled; ii.the grade levels of the students; iii.the primary languages of each LEP student; and iv.the types of English learner programs in which the district has enrolled LEP students, including sheltered English immersion, twoway bilingual, transitional bilingual education (for students with waivers only), or students whose parents have declined services. 2. The district conducts periodic evaluations of the effectiveness of its ELE program. The students are showing English language development and the ability to participate meaningfully in the educational program. Where the district documents that the program is not effective, it takes steps to make appropriate program adjustments or changes that are responsive to the outcomes of the program evaluation. For Title III districts: 3. The district provides information to the Department that describes: (a) ELE programs and activities; (b) a description of the progress made by students in learning English and academic content; (c) the number and percentage of students in the programs attaining English proficiency by the end of the school year; and (d) the description of academic progress made by the students. Authority: M.G.L. c 71A; NCLB, Title III, Title VI; 603 CMR 14.03 District Response Required: Yes Rating: Partially Implemented Department of Education Findings: Interviews and documentation indicate that the district does not have a process in place to conduct periodic evaluations of the effectiveness of its ELE program as required. Medford Public Schools Coordinated Program Review Final Report Page 127 of 152 COMPONENT IX: RECORD KEEPING The criteria in this component examine whether the district maintains required records and documentation for each program area, whether entitlement grants are appropriately designed, amended, and locally monitored, whether the use federal grant funds is in accordance with statutory fund-use rules, including supplement not supplant provisions and maintenance of effort requirements where applicable for the program areas listed below: Title I (Report Issues # TI 39-40 General Requirements and TI 1-18 Fiscal Requirements) Special Education (Report Issues # SE 57-58) Safe and Drug Free Schools (Report Issue # SDF 9-10) Career and Technical Education (Report Issue # CTE 20-23) English Learner Education (Report Issue # 18) Medford Public Schools Coordinated Program Review Final Report Page 128 of 152 SPECIAL EDUCATION IX. RECORD KEEPING CRITERION NUMBER Legal Standard SE 57 Special education child count 1. The school district maintains appropriate procedures to ensure that an accurate and unduplicated child count is provided to the Department of Education upon request. A child count represents students with current, accepted IEPs who are provided, at a minimum, direct special education and/or related services by the district or by an out-of-district provider through a contract with the district. 2. The child count also includes students with disabilities determined eligible for special education who are attending private schools at private expense and are receiving publicly funded services according to IEPs developed by the district. 3. The district does not include as part of its special education child count (a) students who are determined by the Department to be erroneously classified as eligible to be counted under federal or state special education requirements; (b) students who are no longer receiving special education and/or related services; and (c) students with disabilities for whom the district has no programmatic responsibility, even if the district has financial responsibility. State Regulations 603 CMR 23.00 Rating: Implemented Federal Requirements 34 CFR 300.750-754; 300.145; 300.560-300.577 Family Educational Rights and Privacy Act (FERPA); 34 CFR 300.133 District Response Required: No CRITERION NUMBER Legal Standard SE 58 Federal Special Education Entitlement Grant 1. The district’s Special Education entitlement grant is designed by appropriate local administrators who are responsible for the implementation of the local special education programs and services. 2. Where necessary, appropriate local administrators amend the programmatic and budgetary sections of the grant according to procedures and timelines required by the Department of Education. 3. Appropriate local administrators monitor the entitlement grant in an ongoing manner to ensure its full implementation as the Department of Education has approved it. 4. The district has secured the approval of the Department of Education for all amendments prior to their implementation. Medford Public Schools Coordinated Program Review Final Report Page 129 of 152 CRITERION NUMBER Legal Standard State Regulations 28.03(1)(e) Federal Requirements 34 CFR 300.230; 300.340-300.500 Rating: Implemented CRITERION NUMBER District Response Required: No TITLE 1 IX. RECORD KEEPING – General Requirements Legal Standard TI 39 1. The district has submitted all required reports to the Department including the district Title I Plan/Application and Performance and Achievement Report. 2. The district maintains appropriate Title I records in a central location or at each Title I school and keeps correspondence on file, including documentation for identifying schools eligible for Title I services (Target Area Selection) determining school allocations. 3. Current information is made available to the Department regarding the allocation of Title I funds to schools and the rank order list and student selection criteria determined by the district. 1113; 1116 (c)(1)(B) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 40 Federal Title I Grant: 1. The district’s Title I grant is developed by appropriate local administrators who are responsible for the implementation of the local Title I programs and services. 2. Where necessary, appropriate local administrators amend the programmatic and budgetary sections of the grant according to procedures and timelines required by the Department, including those for grant amendments, 3. Appropriate local administrators monitor the grant in an ongoing manner to ensure its full implementation as the Department has approved it. Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 130 of 152 CRITERION NUMBER TITLE 1 IX. RECORD KEEPING – FISCAL REQUIREMENTS I. Maintenance of Effort Legal Standard TI 1 The maintenance of effort fiscal test is of local and state expenditures, not of Title I or other federal expenditures. 1120A(a); 9521 NCLB District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard TI 2 The school district’s combined fiscal effort per student (or aggregate expenditures of the school district and state for free public education for the preceding fiscal year) was not less than 90% of the combined fiscal effort or aggregate expenditures for the second preceding fiscal year. 1120A(a); 9521(a) NCLB District Response Required: No Rating: Implemented CRITERION NUMBER II. Comparability Legal Standard TI 3 1. Documentation of the district’s Comparability Report demonstrates annual compliance with the comparability requirement and is documented at least biennially. 1120A(c)(3)(B) NCLB 2. The district’s comparability fiscal test is a comparison of local and state funds in Title I schools and non-Title I schools, not a comparison of federal funds. 1120A(c) NCLB 3. The school district uses state and local funds in Title I schools that provide services that, taken as a whole, are at least comparable to services in non-Title I schools. 1120A(c)(1)(A) NCLB 4. If all of the district’s schools are Title I schools, the school district uses state and local funds to provide services that, taken as a whole, are substantially comparable in each school. 1120A(c)(1)(B) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 131 of 152 CRITERION NUMBER Legal Standard TI 4 1. The district has established and implemented the following requirements: a. a district-wide salary schedule; b. a policy to ensure equivalence among schools in teachers, administrators, and other staff; and c. a policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies. 1120A(c)(2)(A) NCLB 2. If the school district groups schools by grade-span for demonstrating comparability, the school district does so in a way that reflects the actual grade-spans of the school district. 1120A(c)(1)(C) NCLB; Title I Policy Guidance IASA 3. In applicable situations, the school district divides a grade-span with significant school enrollment differences into a large-group/small-group model. Title I Policy Guidance IASA District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard TI 5 1. Other measures, such as student/instructional staff ratios or student/instructional staff salary ratios, are used to demonstrate comparability. a. Student/staff ratios: The Title I school average, as determined in Comparability Report forms, does not exceed 110% of average of non-Title I schools. b. Student/staff salary ratios: The Title I school averages are at least 90% of the average of non-Title I schools. c. Staff salary differentials for years of employment are not used in implementing requirements under criterion TI 5 (b) above. 1120A(c)(2)(B); 1120A(c)(3)(A) NCLB; Title I Policy Guidance IASA 2. Non-instructional staff (e.g., cafeteria workers, custodians, nurses, playground aides, student teachers, volunteers, etc.) are not included in the district’s comparability determinations. Title I Policy Guidance IASA Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 132 of 152 CRITERION NUMBER Legal Standard TI 6 If the district is receiving and excluding supplemental state and local funds from the Title I comparability determinations, the district is able to demonstrate that the supplemental state and/or local funds that are excluded from Title I comparability determinations are used for programs that meet the intent and purposes of Title I. 1120A(d) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER III. Supplement, Not Supplant Legal Standard TI 7 [Applicable to Targeted Assistance Schools (TAS)] The district is able to demonstrate that it uses Title I funds only to supplement and, to the extent practical, increase the level of funds that would in the absence of Title I funds be made available from non-federal sources for the education of students participating in Title I programs. 1120A(b)(1) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 8 [Applicable to TAS] The district/school is able to demonstrate that the Title I funds have been used for the express purpose of serving those students who were identified as being in greatest need of Title I assistance based on the district’s and school’s Title I student selection criteria. 1115(a) NCLB District Response Required: No Rating: Implemented CRITERION NUMBER Legal Standard TI 9 [Applicable to Schoolwide Title I funds may be used in combination with state, local, and other federal funds to serve the entire school population in accordance with the schoolwide plan in effect for the school. 1114(a)(1) NCLB Medford Public Schools Coordinated Program Review Final Report Page 133 of 152 CRITERION NUMBER Legal Standard Programs (SWP)] The district is able to demonstrate that the Title I funds in a schoolwide program school are in addition to the total amount of funds that would, in the absence of the Title I funds, be made available from non-federal sources for the school, including funds needed to provide services required by law for students with disabilities and students with limited English proficiency. 1114(a)(2)(B) NCLB District Response Required: Rating: Not Applicable No Department of Education Findings: Medford Public Schools does not have any School-wide Program in the Title I Eligible schools CRITERION NUMBER Legal Standard TI 10 (Exclusion) If the district is excluding supplemental state and local funds from the Title I supplement (not supplant determinations), the district is able to demonstrate that the excluded funds are used for programs that meet the intent and purposes of Title I. 1120A 1120A(d) Rating: Not Applicable District Response Required: No Department of Education Findings: The district is not excluding state and local funds from the Title I supplement. CRITERION NUMBER Legal Standard TI 11 In implementing federal Title I supplement, not supplant requirements, the district has developed and implemented a Supplement Not Supplant policy and procedures. Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 134 of 152 CRITERION NUMBER IV. Other Fiscal Requirements Legal Standard TI 12 The district maintains time and effort records for all Title I staff to document the time actually spent by staff on Title I activities. a. Full-time staff – Staff funded solely from the Title I grant sign semi-annual certifications that he/she has been working solely in activities supported by the Title I grant for the period indicated. The certification is signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. b. Split time staff – Title I personnel whose time is charged in part to Title I and in part to other revenue sources (district funds or other federal funds) maintain monthly time and effort records. The employee documents the portions of time and effort dedicated to Title I and other revenue sources and must account for the total time for which the employee is compensated. The time and effort record coincides with one or more pay periods and must be signed by the employee and countersigned by an administrator or supervisor. EDGAR: OMB Circular A-87; MADOE Title I Instructions District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard TI 13 The district has selected eligible schools in accordance with Title I requirements under this criterion. 1113(a); 1113(b); 1113(c); NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 14 The district includes accurate data in its Title I Application (Form 1) for the number of students residing in each of the district’s school attendance areas. 1113(a) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 135 of 152 CRITERION NUMBER Legal Standard TI 15 The district has made appropriate reservations (set asides) on Form 2 in accordance with applicable NCLB requirements: 1. Professional development – highly qualified staff 2. Professional development – schools in need of improvement 3. Choice-related transportation and supplementary services 4. Parental involvement 5. Homeless 1113(c)(2)(A); 1113(c)(3) NCLB Rating: Implemented District Response Required: No CRITERION NUMBER Legal Standard TI 16 The final allocations to schools have been calculated in accordance with Title I requirements, and the final allocation totals appropriately relate to the budget total. 1113(a); 1113(c)(2)(A) NCLB District Response Required: Rating: Implemented No CRITERION NUMBER Legal Standard TI 17 The district has made private school allocations in accordance with Title I requirements. 1120(a); 1120(b); 1120(c) NCLB Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 136 of 152 CRITERION NUMBER Legal Standard TI 18 Budgeting – The district budget process demonstrates appropriate Title I program planning and implementation consistent with identified student needs at each school. Note the following Department procedures in determining compliance under this criterion: Review the latest budget, budget narrative, budget comparison, and list of Title I personnel documents to gain an understanding of the schools and grades participating in Title I programs. Interview school staff to determine which subjects and grades are Title I. 1. Does the current year budget total correspond with the district’s entitlement together with any carryover? If not, obtain explanation. 2. Does the current year budget total correspond with the total funds allocated on Form 1? If not, obtain explanation. 3. Review the allocation for each school. Do the allocated dollars for each school approximate budget of personnel assigned to the school as shown on the personnel list? During the school visit, determine whether the personnel are assigned and teaching the grades and subjects noted. 4. Sample schools to compare the consistency of the listing of personnel to the personnel listed on Form D of the Comparability Report. If not consistent, obtain explanation. MADOE Title I Grant Application Instructions and Guidance District Response Required: Rating: Implemented CRITERION NUMBER No SAFE AND DRUG FREE SCHOOLS IX. RECORD KEEPING Legal Standard SDF 9 Appropriate accounting and budget procedures are being implemented to insure that program expenditures are related to the purpose and intent of the Safe and Drug Free Schools and Communities Act. [(EDGAR 76.730 to 734] Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 137 of 152 CRITERION NUMBER Legal Standard SDF 10 Each recipient provides a set of assurances that the activities or programs to be funded comply with the Principles of Effectiveness and foster a safe and drug-free learning environment that supports academic achievement. [NCLB Title IV Sec. 4114 (d) (1) (6-9) District Response Required: Rating: Implemented CRITERION NUMBER No CAREER AND TECHNICAL EDUCATION IX. RECORD KEEPING Legal Standard CTE 20 Student records contain the items listed in the Student Record Review Checklist. Perkins Section 5; Chapter 74 603 CMR 4.03 (4)©(d; 603 CMR 23.00. Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Although there was evidence of required documentation in select files, it was not consistent for all records reviewed. Several student records contained misfiled information, such as letters and report cards, of other students. Exploratory evaluation results are not shared with parents/guardians nor are parents/guardians required to sign off on final course selection or Tech Prep agreements (before counting students as Tech Prep and allowing them to participate in Tech Prep activities). The 8th grade Stanford 9 was referenced as a tool for placement purposes, but no student records contained a copy of this test or evidence of use in planning. While files contained a Career Plan/Portfolio, there was no evidence that it was used in planning any part of the students’ vocational technical program or that it was shared with teachers or parents/guardians as intended. Some admission’s applications indicated first languages other than English; however, there was no documentation of a Home Language Survey or assessment of student’s English language proficiency. No materials (such as letters home) were translated. Medford Public Schools Coordinated Program Review Final Report Page 138 of 152 CRITERION NUMBER Legal Standard CTE 21 Perkins Local Plans. Local Plan Updates, CYE Reports, CTE –SIMS Records and allocation grants are appropriately designed, amended and locally monitored and the required records and documentation regarding all Perkins activities including plans, reports and allocation, competitive and continuation grants are maintained. Perkins Sections 13, 201 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Based upon interviews and record reviews, there is no formal process for the Perkins Local Plan Update (LPU) development and there is little evidence of a system of support in the development and implementation of the LPU. It was suggested in interviews with staff that some Medford Vocational Technical High School students are reported in SIMS as Medford High School students after ninth grade. Data analysis does show "movement" between the two schools, consisting primarily of students with disabilities. The data and financial review that was conducted by K.P. Marshall Associates PC CPAs found several problematic areas. Please refer to the draft financial and data review report that was sent to Superintendent Belson by Jeffrey Wheeler, State Director of Career/Vocational Technical Education on July 12, 2005. CRITERION NUMBER Legal Standard CTE 22 The district uses Perkins funds in accordance with statutory fund-use rules including supplement not supplant provisions. Perkins Sections 135, 3114 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Based on interviews with administration, while there is a Business Manager, as of February 2005, there is no longer someone responsible for fiscal oversight and management of grants. The data and financial review that was conducted by K.P. Marshall Associates PC CPAs found several problematic areas. Please refer to the draft financial and data review report that was sent to Superintendent Belson by Jeffrey Wheeler, State Director of Career/Vocational Technical Education on July 12, 2005. Medford Public Schools Coordinated Program Review Final Report Page 139 of 152 CRITERION NUMBER Legal Standard CTE 23 The district has adequate resources to enable the programs to meet current industry and Occupational Safety and Health Administration (OSHA) regulations with respect to facilities, safety, equipment and supplies. Chapter 74 603 CMR 4.03 (8) Rating: Not Implemented District Response Required: Yes Department of Education Findings: The inspection of all 12 shops resulted in the finding that none of the facilities were in full compliance with the applicable Occupational Safety and Health Administration (OSHA) regulations. Based on observation, interviews and a review of documentation, Medford Vocational Technical High School lacks adequate resources. When asked if the MVTHS resources were adequate in consideration of this criterion, an administrative staff member stated, “No” without hesitation. However, in discussions regarding two recent DOE grant opportunities, it was stated that MVTHS chose not to apply, viewing the grant application process as largely “political” and favoring the regional vocational high schools. CRITERION NUMBER ENGLISH LEARNER EDUCATION IX. RECORD KEEPING Legal Standard ELE 18 Records of LEP Students 1. Cumulative records of English language learners are maintained in a confidential fashion, as required by the Massachusetts Student Record Regulations, and are available to parents upon request. 2. LEP student records include: (a) home language survey; (b) results of tests and evaluations, including, MELA-O, previous LAS-R and –W, MEPA, MCAS, or other tests chosen by the Board of Education; (c) information about students’ previous school experiences; (d) copies of progress reports and report cards; (e) evidence of follow-up monitoring (if applicable); (f) documentation of a parent’s notice to “opt-out” of English learner education; and (g) Individual Student Success Plans for students who have failed MCAS, if the district is required to complete plans for non-LEP students. Medford Public Schools Coordinated Program Review Final Report Page 140 of 152 CRITERION NUMBER ENGLISH LEARNER EDUCATION IX. RECORD KEEPING Legal Standard Authority: 603 CMR 23.05, 23.07; c 69, § 1I; Title VI Rating: Partially Implemented District Response Required: Yes Department of Education Findings: The student record review indicates that the following required elements were inconsistently documented in the individual student’s file: information about a student’s prior school experience, documentation and/or evidence of follow-up monitoring activities and a Student Success Plan for students who have failed the MCAS. Medford Public Schools Coordinated Program Review Final Report Page 141 of 152 APPENDIX I: NUTRITION PROGRAMS AND SERVICES Code of Federal Regulations: 7 CFR Parts: 210 National School Lunch Program 215 Special Milk Program for Children 220 School Breakfast Program 227 Nutrition Education and Training Program 245 Determining Eligibility for Free and Reduced Price Meals and Free Milk in Schools The criteria in this component of the Coordinated Program Review examine whether the School Food Authority ensures that the requirements for participation in the National School Lunch, School Breakfast, Special Milk and Commodity School Programs are being implemented. These requirements specify program responsibilities of local officials in the areas of program administration, preparation and service of nutritious meals, use of program funds, program monitoring, reporting and record keeping. The findings included in this section of the report have been made through on-site activities completed by the Department’s Nutrition Programs and Services team member. Medford Public Schools Coordinated Program Review Final Report Page 142 of 152 CRITERION NUMBER NUTRITION PROGRAMS AND SERVICES Legal Standard NS 1 All free and reduced price and paid lunches claimed for reimbursement are served to students eligible for free, reduced price and paid lunches respectively; and are counted, recorded, consolidated and reported through a system which consistently yields correct claims. 7 CFR 210.18 (g) (1). Rating: Partially Implemented District Response Required: Yes Department of Education Findings: FREE REDUCED PRICE PROCESS 7CFR 210.7(c)(1)i Beginning in the 2005/2006 academic year, the processing of free/reduced price applications and determination of benefits must be completed by the food service staff. Students either did not have access to benefits or were incorrectly determined by the school principal that signed as the determining official. The district’s School Food Authority must have access to centralized data information of students. The unavailability of centralized information (i.e. enrolled school, sibling information) of each family application made it difficult to determine the correct eligibility of students. In some cases family members in different schools were given different eligibility. CRITERION NUMBER Legal Standard NS 2 Records indicate that lunches claimed for reimbursement within the school food authority contain food items/components as required by program regulations. 7 CFR 210.18 (g) (2) Rating: Implemented Medford Public Schools Coordinated Program Review Final Report District Response Required: No Page 143 of 152 CRITERION NUMBER Legal Standard NS 3 School Food Authorities account for all revenues and expenditures of their nonprofit school food service. In order to participate in the NSLP, the School Food Authority maintains records to demonstrate compliance with program requirements. Retention of these documents is for three years after the close of the fiscal year to which they pertain except in cases where audit findings are unresolved. 7CFR210.9 (a) (17); 210.14, 210.15 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: REQUIRED RECORD 7CFR 210.15 VERIFICATION PROCESS The verification process must be completed more accurately in 2006. The following corrections to the verification process are required: The direct certifications are deducted from the total application count before random sampling is conducted. All eligible applicants and direct certifications were counted and 3% were chosen from the Andrews’ School. Verification tracker must be completed to document contact with the students’ household and/or updates in eligibility as a result of verification. All income on the free/reduced applications must be verified for accuracy. “Other Income” was not included in the income verification of one applicant. Food Stamp verification needs to consist of a documented letter of eligibility. A Xeroxed copy of an EBT card is not valid since it does not have an expiration date. FP-9 FORM The signature of the person completing the FP-9 form is required. Non-reimbursable lunches need to be documented on the FP-9 form. Adult lunches (faculty and staff), as well as second lunches that were purchased by students, must be documented but not claimed. Adult lunches and second lunches were counted as paid lunches at the point of service. A separate cash register button should be added to designate non-reimbursable lunches. CLAIM The current counting systems used to consolidate the free, reduced, unpaid and paid meals does not yield an accurate count. It is recommended that the cash registered is utilized with a benefit issuance roster and eliminate the used of tickets. Please specify the new procedure for meal counting and claiming. RESOURCE MANAGEMENT - 7CFR 210.14 Lunch aid assistants’ salaries are paid with the school lunch revenues. Federal Regulations state “revenues received by the nonprofit school food service are to be used only for the operation or improvement of such service.” Therefore these lunch aid assistants must be under the supervision of the food service director and evaluated as with all other staff members within the school food service. RECORDKEEPING Student enrollment records were not accessible making it problematic to complete the attendance verification by school. Please identify how the school food authority will have access to the required records. Medford Public Schools Coordinated Program Review Final Report Page 144 of 152 CRITERION NUMBER Legal Standard NS 4 The School Food Authority works to strengthen the following school nutrition program participation and management practices: a. school nutrition participation b. nutrition education activities c. productivity evaluation 7CFR 210.19; 7CFR 220.8; 7CFR 210.9 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: FOOD PRODUCTION RECORDS Food production sheets are completed. However, the required USDA forms are not being used. Please specify district training on the use of the required forms. BREAKFAST PROGRAM 7 CFR 220 Please establish an accurate point of service for the breakfast program and ensure that all the required components are taken before the meal is counted. A monthly menu needs to be constructed for breakfast to ensure that the required components are served and documented. The roster must be revised to eliminate the words “free/reduced” to avoid overt identification at the service line. A point of service must be established for paid students. The count for paid students was calculated by dividing the amount of money received by the cost of breakfast. CRITERION NUMBER Legal Standard NS 5 All eligible students have access to the school food services program. 7 CFR 15b; 7 CFR 210.23(c). Rating: Partially Implemented District Response Required: Yes Department of Education Findings: Medford Public Schools Coordinated Program Review Final Report Page 145 of 152 CRITERION NUMBER Legal Standard FREE REDUCED PRICE PROCESS 7CFR 210.7(c)(1)I The direct certification process is incomplete. Families who did not receive benefits must be informed of the direct certification of free eligibility. Please respond by stating a procedure of notification to families of students directly certified for free eligibility. Children from homeless families need to be identified on a signed list from the designated Homeless Liaison for the approved children to be claimed as free eligible. COLUMBUS ELEMENTARY SCHOOL Certification and Benefit Issuance7CFR 245.2 Please refer to S-5 to update corrections for application and benefit issuance errors. Please state the date of corrections in * Date column on S-5 form. Please be advised that according to program regulations, students whose benefits will be increased must be done within 3 operating days while students whose benefits will be decreased must be given 10 operating days. Documentation of the change in status, including the date and the notice to parents, must be maintained. Please also indicate the change in status on the bottom of the free/reduced application. Please see “Eligibility Guidance for School Meals Manual” for specific information. Fiscal action may occur. ROBERTS ELEMENTARY SCHOOL Certification and Benefit Issuance7CFR 245.2 Please refer to S-5 to update corrections of application and benefit issuance errors. Please state the dates of corrections on * Date column on S-5. Please be advised that, according to program regulations, students whose benefits will be increased must be done within 3 operating days while students whose benefits will be decreased must be given 10 operating days. Documentation of the change in status, including the date and the notice to parents, must be maintained. Please also indicate the change in status on the bottom of the free/reduced application. Please see “Eligibility Guidance for School Meals Manual” for specific information. Fiscal action may occur. CRITERION NUMBER Legal Standard NS 6 The School Food Authority ensures that established sanitation and health standards are implemented. Facilities are properly safeguarded against theft, spoilage and other loss. 7 CFR 210.13 Rating: Partially Implemented District Response Required: Yes Department of Education Findings: SANITATION AND SAFETY - 7CFR 210.13(a) Integrated Pest Management System needs to be established by the district . TRAINING - 7 CFR 210.19 (a)(3)(4) Training is required in the use of fire extinguishers. Medford Public Schools Coordinated Program Review Final Report Page 146 of 152 APPENDIX II: SCHOOL DISTRICT PROFILE INFORMATION The information which is provided in this Appendix was drawn from data supplied by the school district. The Department’s visiting team carefully reviewed this data as part of its planning for the onsite visit and in preparing this Coordinated Program Review Report. This district-wide information, together with more detailed school building data, is periodically updated by the school district and is available in an ever current form on the Department’s internet web site at <http://profiles.doe.mass.edu/>. Medford Public Schools Coordinated Program Review Final Report Page 147 of 152 School District Profile Information Definitions of Terms Profiles Introduction The Massachusetts Department of Education collects information about schools and districts. Some of the information collected is published in the School and District Profiles. The information provides a snapshot of the educational picture in communities across the state. Districts view, add, update and delete their own district and school information over the web to make sure that the information is as up-to-date and accurate as possible. In addition, the general public will be able to view Directory information about each school district in the state. Individuals can retrieve for themselves information such as school personnel, school programs (e.g. School Choice and TBE) and the location of specialized services such as Special Education Schools, Collaboratives, and Vocational Training Programs. The list below provides an explanation of information presented in the Profiles. The electronic version of this district’s or charter school’s profile information is available at: http://profiles.doe.mass.edu/home.asp?mode=ot&view=&ot=5 Organization Types Approved Special Responsible for providing an education for students with disabilities. A school Education Schools district (LEA) may place a student in an out-of-state program if it believes that such program is the most appropriate for the student. Charter School Public schools that are created by parents, teachers, businesses, and community leaders and have the freedom to organize their activities around a core mission, curriculum, or teaching method. Their autonomy gives them the freedom to create their own budgets and to hire and fire teachers and staff. Collaborative Collaboratives are formed through an agreement among two or more school committees to provide education for their member school systems. Agreements must be filed with the Commissioner of DOE. A Board representative of each member school committee manages them. Collaborative Programs Regardless of the size of the individual collaborative, each school provides programs that its member districts demand. Private School A non-publicly funded school that provides educational services directly to attending students. Public School Public schools are administered by a Public School District, and provide educational services directly to attending students. Expenses are paid by state appropriation. Public School An administrative unit responsible for managing primary and secondary school Medford Public Schools Coordinated Program Review Final Report Page 148 of 152 Districts services within a defined geographical boundary. There can be two types of School Districts, Operational and Non-Operational district, and expenses are paid by state appropriation. The Data Directory Information DOE Code: The DOE Code, also referred to as the Organization Code, is an eight digit numeric code assigned by the Massachusetts Department of Education to every organization listed in the Directory Profiles, including every district and school in the Commonwealth. For districts and schools, the first four digits represent the District Code and the last four digits represent the School Code. Thus the organization code "02660505" stands for "0266" (Sharon Public Schools) + "0505" (Sharon High). If a form requires the 8digit DOE school code it is calling for the entire organization code. Prior to the 2001 school year, organization codes contained six digits (three for the district and three for the school.) With the exception of some special needs schools, the eight digit codes are the same as the six digit codes with one zero added before the district code and another zero added before the school code. Thus, Sharon High's old six digit organizational code was 266505. Please Note: The Department's Organization Code is not the same as the Institution codes assigned by the College Board for SAT and AP results. Nor is it the same as the NCES code assigned to Massachusetts schools by the U.S. Department of Education. Grades/Schools: This section displays the number and grade range of elementary, middle/junior high and high schools in the district, as well as the total number of schools in the district and the grade range of the school system. An elementary range beginning with "PK" indicates the district has pre-kindergarten. A high school range ending in "13" or "14" indicates the district has a post-graduate program. Kindergarten starting age indicates the age as of a particular date at which children are eligible to begin kindergarten. NOTE: District level data only. Services: Inter-district Choice: indicates whether students from other districts may enroll in the district through the state school choice program, which is voluntary and on a space-available basis. Intra-district Choice: indicates whether the district has a school choice program within the school district for students who live in the district. Vocational Education: indicates whether the district operates a Chapter 74 approved vocational education program. Transitional Bilingual Education (TBE): indicates whether the district operates a TBE program. Under Massachusetts law, a district must provide a TBE program in a particular language if there are 20 or more limited English proficient students in that particular language group enrolled in the district. Limited English proficient students are students whose first language is not English and who cannot perform ordinary class work in English. METCO: indicates whether the district participates in the state METCO program, which promotes voluntary desegregation by enrolling minority students from Boston and Springfield in suburban schools. Medford Public Schools Coordinated Program Review Final Report Page 149 of 152 Relationships: Member of Regional Districts: For local school districts, indicates the name(s) of any academic and/or vocational regional district(s) of which the local school district is a member. For regional school districts, indicates the names of member local school districts. A regional school district provides educational services to more than one town. NOTE: District level data only. Enrollment/Indicators Enrollment by Grade Indicates the enrollment for students in grades Pre-kindergarten (PK), kindergarten through 12, Special Education beyond grade 12 (SP), Career and Technical Education beyond grade 12 (CT) for the listed school year. Enrollment by Race/Ethnicity Indicates the percent of enrollment by race/ethnicity for the listed school year. The reporting categories are those used by the U.S. Bureau of the Census. Selected Populations Indicates the percent of enrollment represented by students in special education programs*, students who are limited English proficient, and students eligible to receive free or reduced price lunch*. Data are for the listed school year. Dropout Rate: Indicates the percentage of students in grades 9-12 who dropped out of school between July 1 and June 30 prior to the listed year and who did not return to school by October 1. Dropouts are defined as students who leave school prior to graduation for reasons other than transfer to another school. Children Attending Public Schools Indicates the percent of school-age children in a city or town attending public schools, for the listed school years. NOTE: District level data only. Attendance/Exclusions: Attendance rate indicates the average percentage of enrolled students, (grades 1-12), present in school for the listed school year. Student Exclusion (count) indicates the number of student exclusions that occurred during the listed school year. An exclusion is defined as the removal of a student for disciplinary purposes permanently, indefinitely or for more than ten consecutive school days. Student Exclusion (rate) indicates the rate of exclusions per 1000 students. Technology: Indicates the number of students for every one computer and the percent of classrooms with Internet access. Data are for the listed school year; "DNR" appears for schools and districts that did not yet report data. Plans of High School Graduates: Indicates the post-graduate intentions of students for the listed school year. Test Results Massachusetts Comprehensive Assessment System (MCAS): Shows percentage of students at each performance level for the current year Select a year to view past year's performance level data Medford Public Schools Coordinated Program Review Final Report Page 150 of 152 Select annual comparisons or the For 2002 only: view Cycle II Performance Rating Reports For 2001 only: select a 'Grade and Subject' to view test item analysis data icon for a graphical display of MCAS results SAT: The district or school's SAT results are displayed for the listed years. Finance - District level data only. Per Pupil Expenditures: are calculated by dividing a district's operating costs by its average pupil membership. Operating costs include expenditures for administration, instruction, pupil services, transportation, plant maintenance, and fixed charges. These costs do not include capital outlay and longterm interest on school debt. Average pupil membership includes students who receive services in the district's schools, as well as students receiving home or hospital instruction. Data for regular education, special education, bilingual education and vocational education students are provided in addition to the total for all day programs, for the listed school years. Teacher Salary: total teaching salaries, divided by the number of full-time equivalent teachers, equals the average teacher salary. Foundation Budget Spending Comparison: The education reform act established a foundation budget for each school district. This budget represents the minimum level of spending needed to provide an adequate education for the district's students. The foundation budget is made up of 19 separate categories. The chart shows the district's actual spending in each category for the listed school year as a percentage of the district's foundation budget. If the percentage exceeds 100%, the district spent more in the category than suggested by the foundation budget. If the percentage is less than 100%, the district spent less. Significant variations between local spending and the foundation budget, or between local spending and the statewide averages, should be reviewed closely. In some cases, the differences may be due to unique circumstances and needs within the district. In other cases, the differences may suggest potential areas for review and improvement. **************** This Coordinated Program Review Final Report is also available at: http://www.doe.mass.edu/pqa/review/cpr/reports/ . Medford Public Schools Coordinated Program Review Final Report Page 151 of 152 SE, MOA, TI, SDFS, CTE, ELE, N - 2005 File Name: Medford Public Schools CPR Final Report 2005.doc Last Revised on: January 6, 2006 Prepared by: DGF; POM/GKH Medford Public Schools Coordinated Program Review Final Report Page 152 of 152